Legal Opinion

Palda v. Commissioner

United States Tax Court

Decided November 30, 1956No. Docket Nos. 13705, 13706, 13707Published

In computing the percentage of gross income required by section 251, Internal Revenue Code of 1939, relating to income from United States possessions, held, a partner's gross income includes his distributive share of the gross income of the partnership.

1Opinion of the Court

Charles H. Palda, Petitioner, v. Commissioner of Internal Revenue, Respondent. S. R. Okes, Petitioner, v. Commissioner of Internal Revenue, Respondent. Day Okes, Petitioner, v. Commissioner of Internal Revenue, Respondent

Palda v. Commissioner

Docket Nos. 13705, 13706, 13707

United States Tax Court

27 T.C. 445; 1956 U.S. Tax Ct. LEXIS 26;

November 30, 1956, Filed

Decisions will be entered for the respondent.

In computing the percentage of gross income required by section 251, Internal Revenue Code of 1939, relating to income from United States possessions, held, a partner's gross income includes his…

2Cases cited16 opinions

  1. Neuberger v. CommissionerSupreme Court of the United States · 1940
  2. Switzer v. CommissionerUnited States Tax Court · 1953
  3. Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
  4. Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
  5. Langer v. CommissionerUnited States Tax Court · 1951

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