Legal Opinion

Batman v. Commissioner

United States Tax Court

Decided March 14, 1950No. Docket Nos. 17751, 17752UnpublishedCited by 1 opinion

Upon the evidence, held: 1. Respondent did not err in determining that during the taxable years 1944 and 1945, there did not exist for income tax purposes a valid partnership between petitioner and his minor son in the operation of a farming and ranching business. 2. Petitioners' son, Gerald, was the owner during the years 1944 and 1945 of 176 acres of land from which $700 in rents was collected in each of the taxable years and was included in the alleged partnership income.

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Upon the evidence, held: 1. Respondent did not err in determining that during the taxable years 1944 and 1945, there did not exist for income tax purposes a valid partnership between petitioner and his minor son in the operation of a farming and ranching business. 2. Petitioners' son, Gerald, was the owner during the years 1944 and 1945 of 176 acres of land from which $700 in rents was collected in each of the taxable years and was included in the alleged partnership income. These rents were the property of Gerald and are not includible in petitioners' income. 3. Respondent erred in…

1Opinion of the Court

Ray L. Batman v. Commissioner. Edith B. Batman v. Commissioner.

Batman v. Commissioner

Docket Nos. 17751, 17752.

United States Tax Court

1950 Tax Ct. Memo LEXIS 251; 9 T.C.M. (CCH) 210; T.C.M. (RIA) 50070;

March 14, 1950

Upon the evidence, held:

1. Respondent did not err in determining that during the taxable years 1944 and 1945, there did not exist for income tax purposes a valid partnership between petitioner and his minor son in the operation of a farming and ranching business.

2. Petitioners' son, Gerald, was the owner during the years 1944 and 1945 of 176 acres of land from which $700 in rents…

2Cases cited5 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Bogardus v. CommissionerSupreme Court of the United States · 1937
  3. Morrison v. CommissionerUnited States Tax Court · 1948
  4. W. B. Harbeson Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1931
  5. Estate of McAdow v. CommissionerUnited States Tax Court · 1949

3Cited by1 opinion

  1. Ellis Campbell, Jr., Collector of Internal Revenue v. Ray L. Batman and Mrs. Ray L. (Edith B.) BatmanCourt of Appeals for the Fifth Circuit · 1956

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