Legal Opinion

Tindall v. Commissioner

United States Tax Court

Decided June 9, 1950No. Docket Nos. 19725, 19726Published

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…

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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

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Tindall v. CommissionerUnited States Tax Court · 1950

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