Pottash Bros. v. Commissioner
United States Board of Tax Appeals
1. Where a partnership computed its net income in the year 1917 upon the basis of net worth on January 1, 1917, and net worth on December 31, 1917, and the net worth at the close of the year was determined upon a different basis from that at the beginning of the year, the increase in the net worth will not necessarily reflect the profits of the partnership for the year.
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1. Where a partnership computed its net income in the year 1917 upon the basis of net worth on January 1, 1917, and net worth on December 31, 1917, and the net worth at the close of the year was determined upon a different basis from that at the beginning of the year, the increase in the net worth will not necessarily reflect the profits of the partnership for the year. For lack of evidence enabling the Board to determine the true gain of the partnership for the year the addition to net income made made by the Commissioner of an amount claimed to represent the cost of merchandise on hand at…
1Opinion of the Court
*198OPINION.
Smith :
The issues involved in these proceedings, stated at length in the preliminary statement, may be briefly stated as follows:(1) What was the correct net worth of the partnership at January 1, 1917?(2) What was the correct net income of the partnership for 1917?(3) Whether the tax returns filed for the partnership and of the individual partners for 1917 were false and fraudulent.(4) Whether' the deficiency determined for the partnership is barred from assessment and collection by the statute of limitations.(5) Whether the distributive share of each partner should be reduced by…
2Cases cited2 opinions
- Estate of DavisSupreme Court of Pennsylvania · 1840
- Levy v. CadetSupreme Court of Pennsylvania · 1828
3Cited by1 opinion
- Pottash Bros. v. CommissionerUnited States Board of Tax Appeals · 1928