Burnette v. Commissioner
United States Tax Court
Held: the business of the Burnette Coal and Heating Company during the years here involved was conducted as a "partnership" as that term is defined in section 3797(a)(2), I.R.C. 1939, with a fiscal year ending on April 30, rather than as a sole proprietorship; the partnership terminated on December 31, 1946, as determined by the respondent; petitioner's individual net income for the calendar years 1945 and 1946 is determined herein; and no part of the deficiencies for the…
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Held: the business of the Burnette Coal and Heating Company during the years here involved was conducted as a "partnership" as that term is defined in section 3797(a)(2), I.R.C. 1939, with a fiscal year ending on April 30, rather than as a sole proprietorship; the partnership terminated on December 31, 1946, as determined by the respondent; petitioner's individual net income for the calendar years 1945 and 1946 is determined herein; and no part of the deficiencies for the calendar years 1944, 1945, and 1946 is due to fraud with intent to evade tax under section 293(b), I.R.C. 1939.
1Opinion of the Court
T. S. Burnette v. Commissioner.
Burnette v. Commissioner
Docket No. 43593.
United States Tax Court
T.C. Memo 1959-130; 1959 Tax Ct. Memo LEXIS 118; 18 T.C.M. (CCH) 574; T.C.M. (RIA) 59130;
June 25, 1959
Held: the business of the Burnette Coal and Heating Company during the years here involved was conducted as a "partnership" as that term is defined in section 3797(a)(2), I.R.C. 1939, with a fiscal year ending on April 30, rather than as a sole proprietorship; the partnership terminated on December 31, 1946, as determined by the respondent; petitioner's individual net income for the calendar years…
2Cases cited6 opinions
- Switzer v. CommissionerUnited States Tax Court · 1953
- Ferguson v. CommissionerUnited States Tax Court · 1950
- Marinzulich v. CommissionerUnited States Tax Court · 1958
- Kellett v. CommissionerUnited States Tax Court · 1945
- Mellon v. CommissionerUnited States Board of Tax Appeals · 1937
1 more not listed; retrieve them via the Exa API.