Legal Opinion

Rosenbaum v. Commissioner

United States Tax Court

Decided April 7, 1952No. Docket Nos. 21840, 21841PublishedCited by 4 opinions

Compromise settlements whereby senior partners released junior partners from liability for losses sustained in prior years, and juniors relinquished rights to profits in a liquidating account arising out of a former partnership and operated as a joint venture, held to be readjustments of interests in the venture and did not give rise to allowable deductions to the senior partners for income tax purposes.

1Opinion of the Court

OPINION.

ARtjndell, Judge:

These proceedings involve directly only two individuals, but indirectly other individuals and several successive partnerships.

The petitioners were the senior partners in a partnership organized in 1936 to conduct a brokerage business. The petitioners supplied the capital. They associated others with them as junior partners under an arrangement which included sharing profits and losses. A part of the business of that partnership was trading in securities on its own account, and that part of the business resulted in losses in the years 1937 through 1939. Such losses,…

2Cited by4 opinions

  1. Turner v. CommissionerUnited States Tax Court · 1960
  2. Lehman v. CommissionerUnited States Tax Court · 1953
  3. Rosenbaum v. CommissionerUnited States Tax Court · 1952
  4. Smith v. CommissionerUnited States Tax Court · 1962

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