Felix v. Commissioner
United States Tax Court
1. In determining deficiencies against petitioners for the taxable period July 26, 1945, to February 28, 1946, respondent refused to recognize Ernest Felix and his wife, Mary Felix, as bona fide partners with petitioners in the business conducted under the name of Brentwood Coal & Coke Company No. 1 and No. 2 and taxed all of the income of that partnership equally to petitioners.
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1. In determining deficiencies against petitioners for the taxable period July 26, 1945, to February 28, 1946, respondent refused to recognize Ernest Felix and his wife, Mary Felix, as bona fide partners with petitioners in the business conducted under the name of Brentwood Coal & Coke Company No. 1 and No. 2 and taxed all of the income of that partnership equally to petitioners. Held, Ernest Felix and Mary Felix were bona fide partners during the taxable period involved, and the partnership income is taxable to the four partners in accordance with their agreement. 2. On December 31, 1943,…
1Opinion of the Court
LeMire, Jvdge:
These consolidated proceedings involve deficiencies in income taxes for the years and in the amounts as follows:
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The contested issues are:
1. Whether respondent erred in refusing to recognize Ernest Felix and his wife, Mary Felix, as bona fide partners in Brentwood Coal & Coke Company No. 1 and No. 2 and taxing their share, of the par-nership income to partners equally.
2. (a) Whether the respondent erred in disallowing as deductions to the partnership, conducted under the name of Brentwood Coal & Coke Company, the amounts of $43,480, $31,076.80, and $8,880 paid by…
2Cases cited12 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- Brown v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
7 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Furman v. CommissionerUnited States Tax Court · 1966
- Mathews v. CommissionerUnited States Tax Court · 1973
- Oakes v. Comm'rUnited States Tax Court · 1965
- Van Zandt v. CommissionerUnited States Tax Court · 1963
- Pityo v. CommissionerUnited States Tax Court · 1978
27 more not listed; retrieve them via the Exa API.