Estate of Melvin W. Ballantyne, Deceased, Jean S. Ballantyne, Independent Jean S. Ballantyne, Court. v. Commissioner of Internal Revenue

BEAM, Circuit Judge.

The Estate of Melvin Ballantyne and the executrix, Jean Ballantyne (collectively “the estate”), appeal a decision from the United States Tax Court. We affirm.

I. BACKGROUND

In 1943, Melvin and his brother Russell formed an oral partnership called Ballan-tyne Brothers Partnership (BBP), which started out as a farming operation, but which grew into oil and gas exploration in the 1950’s. When the oil and gas aspect of the partnership began to take off, Russell was in charge of the farming operation in North Dakota, while Melvin was in charge of the oil and gas exploration in…