(father-son farming operation determined to be partnership for tax purposes and not a joint venture between two individual proprietorships; no formal written partnership agreement; while parties shared farm income equally, most expenses allocated to father resulting in net losses on father's personal return even though father had high non-farm income from CPA practice; no partnership return filed; farm bank account created; insurance policy purchased for farming operation; farming operation registered with state as a partnership; accuracy-related penalty upheld against father; partnership finding resulted in expenses being reported equally to each party and in two of three years at issue, result was income to both father and son rather than income to son and loss to father; case affirmed on appeal, and appellate court determined that notice of deficiency satisfied I.R.C. Sec. 7522 because it clearly stated that basis for deficiency was IRS position that business had operated as partnership).