Switzer v. Commissioner
United States Tax Court
Petitioners L. Glenn Switzer and Howard A. Switzer were partners in the Transit Mixed Concrete Company during 1944 and 1945. Petitioner Ida H. Switzer is the wife of L. Glenn Switzer; and petitioner Florence M. Switzer is the wife of Howard A. Switzer. One-half of each husband's partnership interest constituted community property of said spouses under California law.
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Petitioners L. Glenn Switzer and Howard A. Switzer were partners in the Transit Mixed Concrete Company during 1944 and 1945. Petitioner Ida H. Switzer is the wife of L. Glenn Switzer; and petitioner Florence M. Switzer is the wife of Howard A. Switzer. One-half of each husband's partnership interest constituted community property of said spouses under California law. A partnership return of income for each of the years 1944 and 1945 was filed on or before March 15, 1945, and March 15, 1946, respectively. Individual income tax returns were filed by each of the four petitioners for each of the…
1Opinion of the Court
OPINION.
Rice, Judge:
In amended answers the respondent asserted fraud penalties against L. Glenn Switzer and Howard A. Switzer, but not against their wives. The wives were not partners in the business but merely had a community interest in the income therefrom.
The respondent argues that for the taxable years 1944 and 1945 the net distributable income of the business was $34,425.81 and $83,526.31, respectively; and that since petitioners and their wives, in the aggregate, reported only $13,936.73 on their 1944 returns and $15,322.72 on their 1945 returns, they understated the income from their…
2Cases cited12 opinions
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Ferguson v. CommissionerUnited States Tax Court · 1950
- Nicholson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1937
- Robinette v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- McKnight v. CommissionerUnited States Tax Court · 1947
7 more not listed; retrieve them via the Exa API.
3Cited by107 opinions
- Vannaman v. CommissionerUnited States Tax Court · 1970
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Brountas v. CommissionerUnited States Tax Court · 1979
- Marinzulich v. CommissionerUnited States Tax Court · 1958
- Kilpatrick v. CommissionerUnited States Tax Court · 1954
102 more not listed; retrieve them via the Exa API.