Knipp v. Commissioner
United States Tax Court
1. The decedent and petitioner Howard F. Knipp were on the calendar year basis for reporting income, and the partnership, of which they were the sole members with equal rights to share in profits, operated on the basis of a fiscal year ending January 31. The partnership agreement provided, in effect, that if a partner died during a taxable year of the firm his share of the profits would be the amount which he was entitled to receive as "salary."
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1. The decedent and petitioner Howard F. Knipp were on the calendar year basis for reporting income, and the partnership, of which they were the sole members with equal rights to share in profits, operated on the basis of a fiscal year ending January 31. The partnership agreement provided, in effect, that if a partner died during a taxable year of the firm his share of the profits would be the amount which he was entitled to receive as "salary." Held, that the death of decedent on November 21, 1947, terminated the partnership's taxable year. Held, further, that one-half of the partnership's…
1Opinion of the Court
Estate of Frank H. Knipp, Deceased, Howard F. Knipp, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent. Howard F. Knipp, Petitioner, v. Commissioner of Internal Revenue, Respondent
Knipp v. Commissioner
Docket Nos. 42545, 50153, 50154
United States Tax Court
25 T.C. 153; 1955 U.S. Tax Ct. LEXIS 51;
October 31, 1955, Filed
Decisions will be entered under Rule 50.
1. The decedent and petitioner Howard F. Knipp were on the calendar year basis for reporting income, and the partnership, of which they were the sole members with equal rights to share in profits, operated on the basis of…
2Cases cited28 opinions
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- New York Life Insurance v. DunlevySupreme Court of the United States · 1916
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Guaranty Trust Co. v. CommissionerSupreme Court of the United States · 1938
- Commissioner of Internal Revenue v. TreganowanCourt of Appeals for the Second Circuit · 1950
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