Brown v. Commissioner
United States Board of Tax Appeals
1. The distributive shares of the taxable income of the continuing partners in a partnership (exclusive of salary adjustment on account of deceased partner) were not affected by the retirement at the end of the year of one partner and death during the year of another partner where the articles of copartnership provided for the same distribution to the retiring partner and to the estate of the deceased partner as if retirement and death, respectively, had not occurred. 2. The…
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1. The distributive shares of the taxable income of the continuing partners in a partnership (exclusive of salary adjustment on account of deceased partner) were not affected by the retirement at the end of the year of one partner and death during the year of another partner where the articles of copartnership provided for the same distribution to the retiring partner and to the estate of the deceased partner as if retirement and death, respectively, had not occurred. 2. The unpaid balance of a deceased partner's salary which accrued as a liability of the partnership at his death, held to be…
1Opinion of the Court
*1046OPINION.
Littleton:
The principal issue in these proceedings and the one common to all of them is the amount of taxable income realized by the petitioners from the partnership of Brown Brothers & Co. At the beginning of 1920, the partnership was composed of eight partners, six of whom are petitioners in these proceedings. On April 2, 1920, one partner, Eugene Delano, died and the legal representatives of. his estate are likewise petitioners. Another partner, George H. Frazier, retired on December 31, 1920, but no petition on his behalf is involved in the present proceedings. The partnership…
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