Friedell v. Commissioner of Taxation

This is a review on writ of certiorari to the Tax Court which had affirmed orders of the Commissioner of Taxation (now Commissioner of Revenue) disallowing certain deductions claimed by relators in calculating their 1972 Minnesota income tax liabilities. We affirm.

The facts are not in issue. For the 1972 taxable year relators, all residents and dom-iciliaries of the State of Minnesota, were general partners1 in a Minnesota general partnership which invested as a limited partner in a South Dakota limited partnership. The business purpose of the limited partnership was the purchase, care, and…