Felix v. Commissioner
United States Tax Court
1. Under the evidence, held, petitioner and his wife were partners in the operation of the Brentwood Coal & Coke Co. from September 1, to December 31, 1943. Each partner was entitled to one-half the income from the partnership and the Commissioner erred in taxing petitioner with the one-half of the income which belonged to his wife. 2. On December 15, 1943, petitioner filed an amended Form 1040-ES (Declaration of Estimated Income and Victory Tax by Individual for the…
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1. Under the evidence, held, petitioner and his wife were partners in the operation of the Brentwood Coal & Coke Co. from September 1, to December 31, 1943. Each partner was entitled to one-half the income from the partnership and the Commissioner erred in taxing petitioner with the one-half of the income which belonged to his wife. 2. On December 15, 1943, petitioner filed an amended Form 1040-ES (Declaration of Estimated Income and Victory Tax by Individual for the Calendar Year 1943). He did not at that time remit payment on the balance of estimated tax shown to be due by the estimate,…
1Opinion of the Court
Albert T. Felix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Felix v. Commissioner
Docket No. 13828
United States Tax Court
12 T.C. 933; 1949 U.S. Tax Ct. LEXIS 178;
June 1, 1949, Promulgated
Decision will be entered under Rule 50.
1. Under the evidence, held, petitioner and his wife were partners in the operation of the Brentwood Coal & Coke Co. from September 1, to December 31, 1943. Each partner was entitled to one-half the income from the partnership and the Commissioner erred in taxing petitioner with the one-half of the income which belonged to his wife.
2. On December 15, 1943,…
2Cases cited4 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Parker v. CommissionerUnited States Tax Court · 1946
- Felix v. CommissionerUnited States Tax Court · 1949