Legal Opinion

Hallahan v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1928No. Docket Nos. 6848-6851Published

1. PARTNERSHIP - PROFITS DISTRIBUTIVE TO NONPARTNERS. - Two members of a partnership of four died. Thereupon a new partnership was organized by the two remaining, together with three new parties.

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1. PARTNERSHIP - PROFITS DISTRIBUTIVE TO NONPARTNERS. - Two members of a partnership of four died. Thereupon a new partnership was organized by the two remaining, together with three new parties. By the new articles of partnership it was agreed that the estates of the deceased members of the former partnership would be paid a fixed percentage of the profits of the new partnership for three years, but such estates would assume no liability under the new contract of partnership. This arrangement was agreed to by the executors of the two estates, and distributions were made to the two estates as…

1Opinion of the Court

STEPHEN J. HALLAHAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

ARTHUR K. POPE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

FRANCIS S. SNOW, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

HOLTEN B. PERKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hallahan v. Commissioner

Docket Nos. 6848-6851.

United States Board of Tax Appeals

14 B.T.A. 584; 1928 BTA LEXIS 2953;

December 6, 1928, Promulgated

1. PARTNERSHIP - PROFITS DISTRIBUTIVE TO NONPARTNERS. - Two members of a partnership of four died. Thereupon a new partnership was organized…

2Cases cited19 opinions

  1. Coward v. ClantonCalifornia Supreme Court · 1898
  2. London Assurance Co. v. DrennenSupreme Court of the United States · 1886
  3. Mitchel v. CommissionerUnited States Board of Tax Appeals · 1924
  4. Gritten v. DickersonIllinois Supreme Court · 1903
  5. Hallett v. CumstonMassachusetts Supreme Judicial Court · 1872

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