Sovik v. Shaughnessy. Smith v. Shaughnessy

These cases were reargued in the District Court to afford the plaintiffs the opportunity to raise the question as to the applicability of Section 107(a) of the Revenue Code. As a result of the reargument the original decision was adhered to and the complaints were dismissed.

The taxpayers were each special partners in a law firm which represented the executors of the Estate of Daniel M. Edwards, deceased, from May 27, 1929, to June 13, 1932. As such special partner? they had no interest in any accounts receivable or other assets of the firm at any time. Their interest was confined solely to a…