Legal Opinion

Arnold v. Schepps

Court of Appeals for the Fifth Circuit

Decided March 12, 1948No. 12137PublishedCited by 4 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

This appeal involves federal income taxes for the year 1944. The question presented is whether the court below committed reversible error in upholding the validity of a family partnership for income tax purposes. This question turns upon whether the evidence was sufficient to furnish a rational basis for the finding of the trial court that the partnership in reality included Olga Mae Schepps, who was the daughter of one of the partners and the sister of the other.

The partnership consisted of three persons : father, son, and daughter. The Commissioner made a determination…

2Cases cited3 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  3. Thomas v. FeldmanCourt of Appeals for the Fifth Circuit · 1946

3Cited by4 opinions

  1. Arnold, Acting Collector of Internal Revenue v. GreenCourt of Appeals for the Fifth Circuit · 1951
  2. Walsh v. CommissionerCourt of Appeals for the Eighth Circuit · 1948
  3. Arnold, Acting Collector of Internal Revenue v. GreenCourt of Appeals for the Fifth Circuit · 1951
  4. Frank Scofield, Collector of Internal Revenue for the First Collection District of Texas v. D. E. Blackburn and Zola BlackburnCourt of Appeals for the First Circuit · 1954

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