Legal Opinion

Banfield v. Commissioner

United States Board of Tax Appeals

Decided September 27, 1940No. Docket Nos. 93313, 98688, 99999Published

1. The petitioner and another entered into a partnership agreement in 1929 under which they were to purchase certain wheat lands, leases, equipment, and growing crops in Umatilla County, Oregon. Petitioner made an initial advance to the partnership of $100,000 on which, under the partnership agreement, he was entitled to interest at 6 1/2 percent per annum prior to any division of profits.

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1. The petitioner and another entered into a partnership agreement in 1929 under which they were to purchase certain wheat lands, leases, equipment, and growing crops in Umatilla County, Oregon. Petitioner made an initial advance to the partnership of $100,000 on which, under the partnership agreement, he was entitled to interest at 6 1/2 percent per annum prior to any division of profits. Thereafter, and prior to 1935, the petitioner made further advances to the partnership aggregating approximately $170,000. The net profits of the partnership for the years 1935, 1936, and 1937, were less…

1Opinion of the Court

T. H. BANFIELD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Banfield v. Commissioner

Docket Nos. 93313, 98688, 99999.

United States Board of Tax Appeals

42 B.T.A. 769; 1940 BTA LEXIS 947;

September 27, 1940, Promulgated

1. The petitioner and another entered into a partnership agreement in 1929 under which they were to purchase certain wheat lands, leases, equipment, and growing crops in Umatilla County, Oregon. Petitioner made an initial advance to the partnership of $100,000 on which, under the partnership agreement, he was entitled to interest at 6 1/2 percent per annum prior to…

2Cases cited2 opinions

  1. Gatens Inv. Co. v. CommissionerUnited States Board of Tax Appeals · 1937
  2. Banfield v. CommissionerUnited States Board of Tax Appeals · 1940

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