Weinrich v. Commissioner
United States Tax Court
Geraldine and Oscar, husband and wife in a community property State, each reported one-half of Geraldine's share of income of a partnership, in which Geraldine, her father, and her brother were partners, in their individual returns for the year 1945. In 1949, when Geraldine was no longer a partner, respondent determined that the partnership was not valid as to Geraldine in 1945 and added her share of the partnership income for 1945 to the income reported by her father for…
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Geraldine and Oscar, husband and wife in a community property State, each reported one-half of Geraldine's share of income of a partnership, in which Geraldine, her father, and her brother were partners, in their individual returns for the year 1945. In 1949, when Geraldine was no longer a partner, respondent determined that the partnership was not valid as to Geraldine in 1945 and added her share of the partnership income for 1945 to the income reported by her father for that year, assessed a deficiency against the father, and voluntarily made a refund of taxes to Geraldine and Oscar, which…
1Opinion of the Court
OPINION.
Dkennen, Judge:
Respondent determined deficiencies in the income tax for the year 1945 of Geraldine Snyder Weinrich (hereinafter referred to as Geraldine) and Oscar Weinrich (hereafter referred to as Oscar), each in the amount of $1,138.54. The only issue in this consolidated proceeding is whether the mitigation provisions of sections 1311-1315 of the Internal Revenue Code of 1954 permit the assessment and collection of these deficiencies which would otherwise be barred by the statute of limitations.
The case was submitted on a stipulation of facts with exhibits attached thereto. The…
2Cases cited14 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Daniel M. Cory and Margot Cory, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Cory v. CommissionerUnited States Tax Court · 1958
- United States v. Erma RosenbergerCourt of Appeals for the Eighth Circuit · 1956
- H. T. Hackney Co. v. United StatesUnited States Court of Claims · 1948
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3Cited by5 opinions
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- Fong v. CommissionerUnited States Tax Court · 1998
- Weinrich v. CommissionerUnited States Tax Court · 1961
- Yagoda v. CommissionerUnited States Tax Court · 1962