Legal Opinion
N. M. Sellers and Gladys Sellers v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 4, 1955No. 13858PublishedCited by 5 opinions
1Opinion of the Court
DENMAN, Chief Judge.
Petitioners, husband and wife, each sought a review of decisions of the tax court assessing each for the tax years 1944 and 1945 with one half the income of a partnership of the two petitioners in a Coca Cola bottling and selling enterprise owned by the partners. This court, on the stipulation of the parties, consolidated the petitions, the issues tendered in each being the same.
The petitioners contend that the partnership instead of being between the husband and wife was a four-party family partnership consisting in addition to the petitioners their two children, a son…
2Cases cited3 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Harkness v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Ninth Circuit · 1952
3Cited by5 opinions
- Montgomery Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1980
- Max Kuney, Jr., and Constance K. Kuney, His Wife Max J. Kuney, Sr., Olive R. Kuney v. William E. Frank, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Apicella v. CommissionerUnited States Tax Court · 1957
- A. F. Lowes Lumber Co. v. CommissionerUnited States Tax Court · 1960
- Apicella v. CommissionerUnited States Tax Court · 1957