Bufalino v. Commissioner
United States Tax Court
1. Payments made to a partnership for services rendered primarily by one partner are includable in the income of the partnership rather than directly in the income of the partner. 2. Adjustments to partnership income redetermined. 3. Unreported taxable income of petitioners determined by application of funds method, plus estimated living expenses, redetermined. 4. Petitioners are liable for additions to tax for negligence under section 6653(a), I.R.C. 1954.
1Opinion of the Court
RUSSELL A. BUFALINO and CAROLYN BUFALINO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bufalino v. Commissioner
Docket No. 6174-73.
United States Tax Court
T.C. Memo 1976-110; 1976 Tax Ct. Memo LEXIS 294; 35 T.C.M. (CCH) 494; T.C.M. (RIA) 760110;
April 7, 1976, Filed
1. Payments made to a partnership for services rendered primarily by one partner are includable in the income of the partnership rather than directly in the income of the partner.
2. Adjustments to partnership income redetermined.
3. Unreported taxable income of petitioners determined by application of funds method, plus…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Bixby v. CommissionerUnited States Tax Court · 1972
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Ashby v. CommissionerUnited States Tax Court · 1968
12 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Tucker v. United StatesUnited States Court of Claims · 1985
- Schneer v. CommissionerUnited States Tax Court · 1991
- Schneer v. CommissionerUnited States Tax Court · 1991