Tindall v. Commissioner
United States Tax Court
Respondent determined that a partnership existed between petitioner J. M. Tindall and his son in a cotton oil mill business during the taxable years ended May 31, 1945 and 1946, and distributed two-thirds of the losses incurred by that business to petitioners, in accordance with the purported partnership agreement of May 31, 1944. Held, on the facts, it was not the intention of petitioner J. M. Tindall and of his son, either at the time the agreement was entered into or…
Read the full summary
Respondent determined that a partnership existed between petitioner J. M. Tindall and his son in a cotton oil mill business during the taxable years ended May 31, 1945 and 1946, and distributed two-thirds of the losses incurred by that business to petitioners, in accordance with the purported partnership agreement of May 31, 1944. Held, on the facts, it was not the intention of petitioner J. M. Tindall and of his son, either at the time the agreement was entered into or during the taxable years in question, in good faith and acting with a business purpose to join together in the present…
1Opinion of the Court
Mamie Tindall, Petitioner, v. Commissioner of Internal Revenue, Respondent. J. M. Tindall, Petitioner, v. Commissioner of Internal Revenue, Respondent
Tindall v. Commissioner
Docket Nos. 19725, 19726
United States Tax Court
14 T.C. 1120; 1950 U.S. Tax Ct. LEXIS 178;
June 9, 1950, Promulgated
Decisions will be entered under Rule 50.
Respondent determined that a partnership existed between petitioner J. M. Tindall and his son in a cotton oil mill business during the taxable years ended May 31, 1945 and 1946, and distributed two-thirds of the losses incurred by that business to petitioners, in…
2Cases cited2 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Tindall v. CommissionerUnited States Tax Court · 1950