Legal Opinion
Phillips Et Ux. v. United States
Court of Appeals for the Fifth Circuit
Decided December 14, 1951No. 13491_1PublishedCited by 10 opinions
1Opinion of the Court
JOSEPH C. HUTCHESON, Jr., Chief Judge.
Brought by appellants for a refund of income taxes, the question presented below, on the answer to which the judgment turned, was whether losses incurred in connection with the operation of a ranch were attributable to Phillips’ wife and daughter, as a partnership, or to Phillips.
The district judge held that the partnership of wife and daughter was valid for federal income tax purposes, and that the losses were properly distributed between the wife and daughter, and, further, that, in any event, taxpayers are estopped to deny that this is so.
Taxpayer…
2Cases cited9 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
4 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Alexander v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
- Sangers Home for Chronic Patients v. Comm'rUnited States Tax Court · 1979
- Wofford v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. WoffordCourt of Appeals for the Fifth Circuit · 1953
- Gindes v. United StatesUnited States Court of Claims · 1981
- J. Sterling Halstead and Marcella S. Halstead v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
5 more not listed; retrieve them via the Exa API.