Todd v. Commissioner
United States Tax Court
Held, on remand, that the respective amounts of petitioners' distributive shares of partnership income allocated by respondent to petitioners' separate invested capital, community invested capital, and managerial services were reasonable and were the proper amounts attributable to the three sources of partnership income.
1Opinion of the Court
OPINION.
AeuNdell, Judge:
In our original opinion in these proceedings we pointed out that the Commissioner made his allocation of the petitioners’ distributive shares of partnership net income between invested capital and services in accordance with principles laid down in G. C. M. 9825, X-2 C. B. 146, approved in Clara B. Parker, Executrix, 31 B. T. A. 644. In determining the deficiencies, respondent allocated net book profits for each of the years 1936 through 1941 between income from capital and income from services, in the ratio which an 8 per cent return on annual average invested capital…
2Cited by12 opinions
- Eaton v. CommissionerUnited States Tax Court · 1948
- Van Vorst v. CommissionerUnited States Tax Court · 1946
- Battelle v. CommissionerUnited States Tax Court · 1947
- Tinling v. CommissionerUnited States Tax Court · 1946
- Manning v. CommissionerUnited States Tax Court · 1947
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