Palda v. Commissioner
United States Tax Court
In computing the percentage of gross income required by section 251, Internal Revenue Code of 1939, relating to income from United States possessions, held, a partner's gross income includes his distributive share of the gross income of the partnership.
1Opinion of the Court
OPINION.
OppeR, Judge:
Although the operations in the Panama Canal Zone giving rise to the income in controversy were conducted by not one but three partnerships, or more precisely by a joint venture composed of two other partnerships, it is not that factor that poses the problem before us. One of those partnerships also conducted business in the United States. And because the net income of that partnership from its domestic business was presumably a smaller proportion of its gross than that of the Canal Zone joint venture, petitioners can concededly succeed here in keeping their Canal Zone…
2Cases cited15 opinions
- Neuberger v. CommissionerSupreme Court of the United States · 1940
- Switzer v. CommissionerUnited States Tax Court · 1953
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
- Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
- Langer v. CommissionerUnited States Tax Court · 1951
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3Cited by1 opinion
- Palda v. CommissionerUnited States Tax Court · 1956