Noonan v. Commissioner
United States Tax Court
The corporate petitioners received distributive shares of income as limited partners in partnerships of which the individual petitioners were general partners. Held, the amounts which corporate petitioners received are taxable to the corporations' sole shareholders, who are the individual petitioners herein.
1Opinion of the Court
OPINION
The primary issue in this case is whether amounts which the corporate petitioners received and reported on their Federal income tax returns should be taxable to the corporations’ sole shareholders, who are the individual petitioners herein. Such amounts represented the corporations’ distributive shares of income as limited partners in partnerships of which the individual petitioners were general partners.
Despondent’s position with respect to this issue rests on two alternative theories. The first is that the corporations should not be recognized as entities for Federal tax purposes.…
2Cases cited12 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
7 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Recklitis v. CommissionerUnited States Tax Court · 1988
- American Sav. Bank v. CommissionerUnited States Tax Court · 1971
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983
29 more not listed; retrieve them via the Exa API.