Legal Opinion
United States v. Atkins
Court of Appeals for the Fifth Circuit
Decided October 30, 1951No. 13326PublishedCited by 14 opinions
1Opinion of the Court
HOLMES, Circuit Judge.
In our former opinion we held that Ateo Investment Company did not become a partner in the various operating partnerships in which appellee was a partner; but, regardless of that, the question remains whether or not Ateo Investment Company was a valid partnership between its members. If so, the income is taxable to its members. The Supreme Court has recently laid down the tests for determining whether a valid partnership was formed. Commissioner of Internal Revenue v. Culbertson, 337 U.S. 733, 67 S.Ct. 1210, 93 L.Ed. 1659.
The court below found that Ateo Investment…
2Cases cited3 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Rupple v. KuhlCourt of Appeals for the Seventh Circuit · 1949
3Cited by14 opinions
- Bayou Verret Land Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1971
- Donald L. Evans and Joan Evans v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
- Seabrook v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952
- Klein v. CommissionerUnited States Tax Court · 1952
- Elliston v. CommissionerUnited States Tax Court · 1984
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