Jacobs v. Commissioner
United States Tax Court
Taxpayers, husband and wife, filed their separate returns on the calendar year basis. The husband was a member of a partnership which filed its returns on the basis of a fiscal year ending March 31. The partnership was dissolved, liquidated, and terminated on May 31, 1941. Held, that, the partnership having been completely terminated on May 31, 1941, the period from April 1 to May 31, 1941, is a taxable year and, since the right to his distributive share of the partnership…
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Taxpayers, husband and wife, filed their separate returns on the calendar year basis. The husband was a member of a partnership which filed its returns on the basis of a fiscal year ending March 31. The partnership was dissolved, liquidated, and terminated on May 31, 1941. Held, that, the partnership having been completely terminated on May 31, 1941, the period from April 1 to May 31, 1941, is a taxable year and, since the right to his distributive share of the partnership net income earned during such period accrued to the husband on May 31, 1941, one-half of such distributive share is…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
It is the contention of the petitioners that they are required to include in their respective returns for the calendar year 1941 only their share of the earnings of the partnership of which the husband was a partner for the fiscal year ended March 31, 1941, and that the earnings of the partnership of $6,182.36 for the period April 1 to May 31,1941, are taxable to them in the calendar year 1942, for the reason that the “taxable year” of the partnership did not terminate on May 31, J.941, by reason of its dissolution but continued to March 31, 1942, the date of the…
2Cases cited8 opinions
- Heiner v. MellonSupreme Court of the United States · 1938
- Guaranty Trust Co. v. CommissionerSupreme Court of the United States · 1938
- Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923
- Economy Sav. & Loan Co. v. CommissionerUnited States Tax Court · 1945
- General Aniline & Film Corp. v. CommissionerUnited States Tax Court · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Karsch v. CommissionerUnited States Tax Court · 1947
- Glenfield Machine & Tool Co. v. War Contracts Price Adjustment BoardUnited States Tax Court · 1951
- Knipp v. CommissionerUnited States Tax Court · 1955
- Schulz v. CommissionerUnited States Tax Court · 1960
- Méndez Ríos v. Secretario de HaciendaSupreme Court of Puerto Rico · 1954
7 more not listed; retrieve them via the Exa API.