Davison v. Commissioner
United States Tax Court
Held, under the facts petitioner was not a limited partner in a partnership organized under the laws of the State of New York on July 1, 1943, under the firm name of "Tegumat", succeeding a general partnership of the same name of which her then husband and two others were the general partners.
Read the full summary
Held, under the facts petitioner was not a limited partner in a partnership organized under the laws of the State of New York on July 1, 1943, under the firm name of "Tegumat", succeeding a general partnership of the same name of which her then husband and two others were the general partners. Not being a bona fide partner in said partnership she was not taxable on her alleged distributable share of the profits of the partnership for 1945. The Commissioner is not sustained in his determination of the deficiency and a five per cent negligence penalty.
1Opinion of the Court
Eleanor Sparks Davison (formerly Eleanor Sparks Martin) v. Commissioner.
Davison v. Commissioner
Docket No. 37291.
United States Tax Court
1953 Tax Ct. Memo LEXIS 329; 12 T.C.M. (CCH) 293; T.C.M. (RIA) 53089;
March 20, 1953
Held, under the facts petitioner was not a limited partner in a partnership organized under the laws of the State of New York on July 1, 1943, under the firm name of "Tegumat", succeeding a general partnership of the same name of which her then husband and two others were the general partners. Not being a bona fide partner in said partnership she was not taxable on her alleged…
2Cases cited3 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Glensder Textile Co. v. CommissionerUnited States Board of Tax Appeals · 1942
- Roughan v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952