Ransohoffs, Inc. v. Commissioner
United States Tax Court
In about 1902 the father of Robert, James, and Howard Ransohoff established the business of Ransohoffs. Later Robert and James and their father formed a partnership to conduct the business. The father died and in the early 1920's Howard joined the firm. In 1930 a written partnership agreement was executed by the three brothers. On May 20, 1938, they executed a further partnership agreement, providing for the continuation of the partnership after the death of a partner.
Read the full summary
In about 1902 the father of Robert, James, and Howard Ransohoff established the business of Ransohoffs. Later Robert and James and their father formed a partnership to conduct the business. The father died and in the early 1920's Howard joined the firm. In 1930 a written partnership agreement was executed by the three brothers. On May 20, 1938, they executed a further partnership agreement, providing for the continuation of the partnership after the death of a partner. On October 9, 1938, Howard died. Upon his death no liquidation of the firm occurred, its assets were not distributed, and it…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
It is unnecessary to enter into any extended discussion of sections 740 and 744 of the Internal Revenue Code, under which the controversy in the case at bar arises. The precise issue is whether the petitioner is entitled thereunder to compute its excess profits credit by the income method, ns provided in section 713, or by the invested capital method, as provided in section 714. The petitioner contends that it is entitled to use the income method. In order to do so the preceding partnership must be regarded as a “qualified component corporation” as defined in section…
2Cases cited4 opinions
- Burwell v. CawoodSupreme Court of the United States · 1844
- Ford v. Comm'rUnited States Tax Court · 1946
- Lehman v. CommissionerUnited States Tax Court · 1946
- Faigle Tool & Die Corp. v. CommissionerUnited States Tax Court · 1946
3Cited by9 opinions
- E. T. Renfro Drug Co. v. CommissionerUnited States Tax Court · 1948
- Hawaiian Freight Forwarders, Ltd. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1952
- E. T. Renfro Drug Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Hawaiian Freight Forwarders, Ltd. v. CommissionerUnited States Tax Court · 1950
- E. T. Renfro Drug Co. v. CommissionerUnited States Tax Court · 1948
4 more not listed; retrieve them via the Exa API.