Legal Opinion

Fainblatt v. Commissioner

United States Tax Court

Decided March 22, 1957No. Docket Nos. 55733, 55734Published

Facts found in an earlier proceeding involving the same partnership, including a finding of a business purpose, stipulated in this proceeding as being correct, held, to justify present finding that the general partners are not taxable on partnership income credited to their wives as limited partners, notwithstanding a contrary result in the earlier proceeding prior to Commissioner v. Culbertson, 337 U.S. 733.

1Opinion of the Court

Leon Fainblatt, Petitioner, v. Commissioner of Internal Revenue, Respondent. Irving Fainblatt, Petitioner, v. Commissioner of Internal Revenue, Respondent

Fainblatt v. Commissioner

Docket Nos. 55733, 55734

United States Tax Court

27 T.C. 989; 1957 U.S. Tax Ct. LEXIS 237;

March 22, 1957, Filed

Decisions will be entered under Rule 50.

Facts found in an earlier proceeding involving the same partnership, including a finding of a business purpose, stipulated in this proceeding as being correct, held, to justify present finding that the general partners are not taxable on partnership income credited to…

2Cases cited2 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Fainblatt v. CommissionerUnited States Tax Court · 1957

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