Estate of Klein v. Commissioner
United States Tax Court
Deceased taxpayer was a partner, with a 30-percent interest, in two partnerships. A partnership return was filed showing gross receipts from sales and contracting income in the amount of $ 3,545,911.45. The deceased taxpayer and his surviving spouse filed a joint Federal income tax return showing items of gross income in the total amount of $ 91,531.15, of which $ 90,845.89 was partnership gross income.
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Deceased taxpayer was a partner, with a 30-percent interest, in two partnerships. A partnership return was filed showing gross receipts from sales and contracting income in the amount of $ 3,545,911.45. The deceased taxpayer and his surviving spouse filed a joint Federal income tax return showing items of gross income in the total amount of $ 91,531.15, of which $ 90,845.89 was partnership gross income. The amount omitted from the joint return was $ 45,733.28. Petitioners contend the "amount of gross income stated in the return" was $ 91,531.15. Respondent contends it was $ 1,106,896.07. The…
1Opinion of the Court
Dawson, Judge:
The severed issues in these cases were assigned to and heard by Commissioner Charles R. Johnston pursuant to Rules 180 and 182, Tax Court Rules of Practice and Procedure. With minor modifications the Court agrees with and adopts the report of Commissioner Johnston which is set forth below.
OPINION OF THE COMMISSIONER
Respondent determined the following deficiencies and additions to tax against petitioners for the taxable years 1955 through 1960:
Docket No. Year Deficiencies Additions to tax under sec. 6653(b)[1]
2696-64
1959 $9,547.71 $5,266.92
1960 14,367.61 7,183.81
1955 48,594.11…
2Cases cited29 opinions
- Williamson v. Lee Optical of Oklahoma, Inc.Supreme Court of the United States · 1955
- National Labor Relations Board v. Jones & Laughlin Steel Corp.Supreme Court of the United States · 1937
- Reed v. ReedSupreme Court of the United States · 1971
- McDonald v. Board of Election Comm'rs of ChicagoSupreme Court of the United States · 1969
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
24 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Hoffman v. Comm'rUnited States Tax Court · 2002
- Estate of Herman Klein, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Insulglass Corp. v. CommissionerUnited States Tax Court · 1985
- Black v. CommissionerUnited States Tax Court · 1977
- Harlan v. Comm'rUnited States Tax Court · 2001
23 more not listed; retrieve them via the Exa API.