Bloomfield Ranch v. Commissioner

Bloomfield Ranch et al. v. Commissioner.

Bloomfield Ranch v. Commissioner

Docket No. 5007.

United States Tax Court

1947 Tax Ct. Memo LEXIS 322; 6 T.C.M. (CCH) 84; T.C.M. (RIA) 47018;

January 31, 1947

Eustace Cullinan, Esq., and O. K. Cushing, Esq., 1 Montgomery St., San Francisco 4, Calif., for the petitioners. Leonard A. Marcussen, Esq., for the respondent.

HARRON

Memorandum Findings of Fact and Opinion

HARRON, Judge: Apartnership income tax return was filed for Bloomfield Ranch for the year 1940. The respondent has held that Bloomfield Ranch is an association as defined in section 3797(a)(3) of the…