Smith v. Commissioner
United States Tax Court
1. Section 731 of the 1954 Code not applicable with respect to partnership taxable year beginning October 1, 1954. 2. Petitioner E. Comer Smith not entitled to deduct credit balance in his partnership capital account equal to deficit balance in other partner's capital account upon closing of partnership books in 1955. Deficit represented other partner's 50-percent share of partnership losses over the years which Smith made no effort to collect.
1Opinion of the Court
E. Comer Smith and the Estate of Carrie Smith, Deceased, Caleb R. Kelly, Jr., Executor v. Commissioner.
Smith v. Commissioner
Docket No. 86872.
United States Tax Court
T.C. Memo 1962-270; 1962 Tax Ct. Memo LEXIS 38; 21 T.C.M. (CCH) 1436; T.C.M. (RIA) 62270;
November 19, 1962
1. Section 731 of the 1954 Code not applicable with respect to partnership taxable year beginning October 1, 1954.
2. Petitioner E. Comer Smith not entitled to deduct credit balance in his partnership capital account equal to deficit balance in other partner's capital account upon closing of partnership books in 1955. Deficit…
2Cases cited7 opinions
- Leonard A. Farris and Katherine Farris v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1955
- Shippen v. CommissionerUnited States Tax Court · 1958
- A. D. Juilliard & Co. v. Orem'sCourt of Appeals of Maryland · 1889
- Farris v. CommissionerUnited States Tax Court · 1954
- Frank J. Shippen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
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