Neil v. United States

WESTOVER, District Judge.

Plaintiff William P. Neil and LeRoy D. Owen were partners in a real estate brokerage business, doing business under the name of “LeRoy D. Owen Company.” LeRoy D. Owen was the only general partner and William P. Neil the only limited partner. The partnership was not licensed by the Division of Real Estate of the State of California to do a real estate brokerage business; but LeRoy D. Owen held a real .estate broker’s license, doing business as LeRoy D. Owen Company.

A partnership income tax return was filed for the year 1946, which disclosed the income of the…