Edward T. And Billie R. Pratt, William D. And Anita Pratt, Jack E. And Crystal A. Pratt v. Commissioner of Internal Revenue

TUTTLE, Circuit Judge:

In this consolidated tax case of three brothers and their wives the Pratts appeal from an adverse decision by the Tax Court.

The facts are not in dispute. The Commissioner has conceded error with respect to one prong of the Tax Court decision, and there remains as the sole issue on this appeal, the correctness of the Tax Court’s decision that the management fees payable to the taxpayer husbands (hereinafter taxpayers), general partners in two limited partnerships, were includable in their income as part of their distributive share of partnership profits, or, in the…