Legal Opinion

Miranda v. Commissioner

United States Tax Court

Decided August 13, 1965No. Docket Nos. 2174-62, 1567-63Unpublished

Held, petitioner has failed to prove: 1. That a true partnership, recognizable for tax purposes, existed between petitioner and his cousin, and 2. That respondent erred in disallowing certain claimed deductions for business entertainment and gratuities. Business income distributable to petitioner's cousin as an alleged partner in petitioner's insurance brokerage business was actually income of petitioner.

1Opinion of the Court

A. Michael Miranda v. Commissioner.

Miranda v. Commissioner

Docket Nos. 2174-62, 1567-63.

United States Tax Court

T.C. Memo 1965-220; 1965 Tax Ct. Memo LEXIS 108; 24 T.C.M. (CCH) 1126; T.C.M. (RIA) 65220;

August 13, 1965

Held, petitioner has failed to prove: 1. That a true partnership, recognizable for tax purposes, existed between petitioner and his cousin, and 2. That respondent erred in disallowing certain claimed deductions for business entertainment and gratuities. Business income distributable to petitioner's cousin as an alleged partner in petitioner's insurance brokerage business was…

2Cases cited7 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Commissioner v. TowerSupreme Court of the United States · 1946
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
  5. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954

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