Legal Opinion

Kresser v. Commissioner

United States Tax Court

Decided August 20, 1970No. Docket Nos. 2019-68, 2020-68, 2283-68Published

Petitioners held interests in two partnerships. Prior to 1965 each partner was allocated a distributive share of the partnerships' income in accordance with his percentage interest in such partnerships.

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Petitioners held interests in two partnerships. Prior to 1965 each partner was allocated a distributive share of the partnerships' income in accordance with his percentage interest in such partnerships. One W. H. Appleton, another partner, was the dominant figure in these partnerships and had a large net operating loss carryover that would expire by the end of 1965. In order to permit him to take advantage of that carryover, a "Board of Governors" that was concerned with various Appleton enterprises voted to allocate all of the 1965 income in the two partnerships to Appleton. In return it was…

1Opinion of the Court

Jean V. Kresser and Blanche Kresser, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Kresser v. Commissioner

Docket Nos. 2019-68, 2020-68, 2283-68

United States Tax Court

54 T.C. 1621; 1970 U.S. Tax Ct. LEXIS 79;

August 20, 1970, Filed

Decisions will be entered for the respondent.

Petitioners held interests in two partnerships. Prior to 1965 each partner was allocated a distributive share of the partnerships' income in accordance with his percentage interest in such partnerships. One W. H. Appleton, another partner, was the dominant figure in these partnerships and had a large…

2Cases cited8 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
  3. Pollack v. CommissionerUnited States Tax Court · 1966
  4. Foxman v. CommissionerUnited States Tax Court · 1964
  5. Hyman Smith and Lillian Smith v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Morris Smith and Esther SmithCourt of Appeals for the Seventh Circuit · 1964

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