Slifka v. Commissioner of Internal Revenue (Two Cases)

The only question upon these appeals is whether the partnerships formed by the taxpayers in 1943 were within the statutory definition of that word. 1 The Supreme Court has recently three times dealt with similar situations, 2 and from these deci sions we understand that they present instances of the more general test laid down in Gregory v. Helvering : 3 i. e., whether an association, or joint venture, which satisfies all formal requirements and may be valid as between the parties, has been created to promote the conduct of their business in any other way than by reducing taxes. That this…