Nicholson v. Commissioner
United States Board of Tax Appeals
1. Petitioners filed joint returns for 1928 to 1930, inclusive, and separate returns on the community property basis for 1931 and 1932. Throughout the taxable years, the petitioner, T. G. Nicholson, was a partner with his brother-in-law, Clopton, in the operation of a ferry. Though the partnership earned taxable income during each such year, it was not reported in the joint or separate returns, but Clopton did report it as his income and paid tax thereon.
Read the full summary
1. Petitioners filed joint returns for 1928 to 1930, inclusive, and separate returns on the community property basis for 1931 and 1932. Throughout the taxable years, the petitioner, T. G. Nicholson, was a partner with his brother-in-law, Clopton, in the operation of a ferry. Though the partnership earned taxable income during each such year, it was not reported in the joint or separate returns, but Clopton did report it as his income and paid tax thereon. The omission of this taxable income from the returns of the petitioner, T. G. Nicholson, after those for 1928, was willful and knowingly…
1Opinion of the Court
*192OPINION.
Leech :
The petitioner, T. G. Nicholson, was at all times mentioned herein, an officer of the Gretna Trust & Savings Bank and president of that bank from 1921 through 1932. Since all- of the acts or omissions hereinafter detailed were those of the petitioner, T. G. Nicholson, he will be referred to as the petitioner.
In October 1927, the petitioner and his brother-in-law, B. W. Clopton, formed a partnership under the name of Melville Ferry Co., *193for tbe purpose of operating a ferry at Melville, Louisiana. Each was to have a 50 percent interest and the profits were to be divided equally…
2Cases cited3 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Oscanyan v. Arms Co.Supreme Court of the United States · 1881
- Crocker v. United StatesSupreme Court of the United States · 1916
3Cited by12 opinions
- Mauch v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Rugel v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1942
- Dukehart-Hughes Tractor & Equipment Co., Inc., a Corporation v. The United StatesUnited States Court of Claims · 1965
- Commissioner of Internal Rev. v. Textile Mills S. Corp.Court of Appeals for the Third Circuit · 1940
- Commissioner of Internal Rev. v. Textile Mills S. Corp.Court of Appeals for the Third Circuit · 1940
7 more not listed; retrieve them via the Exa API.