Calaf Collazo v. Secretary of Treasury

In November 1934 Federico and Jaime Calaf Collazo inherited from their father the Central Monserrate and 5,224 cuerdas of land, which they continued to operate for profit. In view of the fact that they only rendered individual income-tax returns for the taxable calendar years 1938 to 1943, the Treasurer — now Secretary of the Treasury — notified them with official returns as a joint venture, as well as for personal deficiencies. As to whether or not they constituted a joint venture, in the opinion rendered by us in Calaf v. Tax Court, 73 P.R.R. 758, we stated at p. 758 that:

“. . . . The mere…