Wild v. Commissioner of Internal Revenue

L. BAND, Circuit Judge.

The question. raised by this appeal is whether the earned, but undistributed, income of a member of two investment “syndicates” using contributions of its members to-buy, hold and sell securities and land, is taxable., The taxpayer’s position is that he need return only what is actually distributed- by the “syndicate manager’?; the Commissioner’s that the syndicate was a partnership, and that its realized profits were taxable income of the members, though, retained by '.the manager, for future investment, or -eventual distribution. The Board took the 'Commissioner’s…