United States v. Atkins

HOLMES, Circuit Judge.

The appellant’s petition for rehearing correctly interprets our opinion of August 31, 1951, as not an abandonment of our former holding that neither Ateo nor the son became partners in the operating partnerships, and that appellee continued as the partner therein. Now, for the purposes of its petition for a rehearing, the appellant áccepts this court’s holding that Ateo was a valid partnership and that appellee’s son was entitled as a partner to share in its income. Thus for the purpose of tihe present petition for rehearing, and therefore for tax purposes, we have two…