Legal Opinion

Bloomfield Ranch v. Commissioner of Internal Rev.

Court of Appeals for the Ninth Circuit

Decided April 20, 1948No. 11643PublishedCited by 5 opinions

1Opinion of the Court

GARRECHT, Circuit Judge.

The Respondent determined that the Petitioners constituted an association taxable as a corporation under Section 3797(a) (3) Internal Revenue Code, 26 U.S.C.A. Int. Rev. Code, § 3797(a) (3), and claimed for the taxable year 1940 a deficiency of $6,-646.60 in income tax and $4,159.58 declared value excess profits tax.

The Petitioners, claiming that their organization is a partnership under Section 3797(a) (2) Internal Revenue Code, 1 and not a corporation, petitioned the Tax Court to redetermine the tax deficiency.

There is no dispute about the amounts. The Petitioners…

2Cases cited19 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Morrissey v. CommissionerSupreme Court of the United States · 1935
  3. Swanson v. CommissionerSupreme Court of the United States · 1935
  4. Helvering v. CombsSupreme Court of the United States · 1935
  5. Tompkins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1938

14 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Arthur Rohman and Jevne Shepherd Rohman, as Co-Trustees of Ida S. Shepherd Trust v. United StatesCourt of Appeals for the Ninth Circuit · 1960
  2. Bolger v. CommissionerUnited States Tax Court · 1973
  3. Bolger v. CommissionerUnited States Tax Court · 1973
  4. Larson v. CommissionerUnited States Tax Court · 1976
  5. Larson v. CommissionerUnited States Tax Court · 1976

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API