Legal Opinion

Willis v. Commissioner

United States Tax Court

Decided November 29, 1957No. Docket Nos. 54624-54626UnpublishedCited by 1 opinion

In 1944, 1946, and 1947, petitioners Elmer D. and Charles Wesley Willis operated a partnership in North Carolina which was primarily engaged in buying for and shipping seafood to dealers outside of North Carolina. The partnership also bought and sold clams for its own account. Petitioners kept no books and records except copies of shipping memoranda which reflected the quantity and price of seafood shipped.

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In 1944, 1946, and 1947, petitioners Elmer D. and Charles Wesley Willis operated a partnership in North Carolina which was primarily engaged in buying for and shipping seafood to dealers outside of North Carolina. The partnership also bought and sold clams for its own account. Petitioners kept no books and records except copies of shipping memoranda which reflected the quantity and price of seafood shipped. Respondent determined the petitioners' distributive shares of partnership income by using the total value of seafood shipments shown on the shipping memoranda as representing the amount of…

1Opinion of the Court

Elmer D. Willis and wife, Pearl Willis v. Commissioner. Charles Wesley Willis and wife, Edna M. Willis v. Commissioner. Charles Wesley Willis v. Commissioner.

Willis v. Commissioner

Docket Nos. 54624-54626.

United States Tax Court

T.C. Memo 1957-223; 1957 Tax Ct. Memo LEXIS 32; 16 T.C.M. (CCH) 1013; T.C.M. (RIA) 57223;

November 29, 1957

In 1944, 1946, and 1947, petitioners Elmer D. and Charles Wesley Willis operated a partnership in North Carolina which was primarily engaged in buying for and shipping seafood to dealers outside of North Carolina. The partnership also bought and sold clams for its…

2Cited by1 opinion

  1. In Re Estate of Lillian Virginia Sperling, Deceased. Warren Richard Sperling, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965

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