Farnsworth v. Commissioner

OPINION.

Opper, Judge:

The parties are in accord on a number of subordinate questions. Respondent apparently concedes that a partnership agreement can be amended during the term of a partnership to alter the respective interests in partnership income or loss. See, e. g., John G. Curtis, 12 T. C. 810, affd. (C. A. 7) 183 F. 2d 7; Frederick S. Klein, 25 T. C. 1045. Petitioner on the other hand appears to accept the proposition that a partner may not deduct as a personal expense or loss any part of tRe partnership expenditures. Western Construction Co., 14 T. C. 453, 471, affirmed per curiam (C.…