Palm Beach Aero Corp. v. Commissioner
United States Tax Court
1. The majority stockholders of the petitioner, which was engaged in the business of furnishing supplies, materials and a training base for the Civil Air Patrol, organized a partnership which took over the petitioner's operating activities.
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1. The majority stockholders of the petitioner, which was engaged in the business of furnishing supplies, materials and a training base for the Civil Air Patrol, organized a partnership which took over the petitioner's operating activities. Held, the respondent erred in refusing to recognize the partnership for tax purposes, and in holding the petitioner taxable on the net income of the partnership either under section 22 (a) or section 45, Internal Revenue Code. 2. Held, further, there being no excess profits tax due for 1943, the petitioner is not subject to the 25 per cent delinquency…
1Opinion of the Court
Palm Beach Aero Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Palm Beach Aero Corp. v. Commissioner
Docket No. 24578
United States Tax Court
17 T.C. 1169; 1952 U.S. Tax Ct. LEXIS 293;
January 15, 1952, Promulgated
Decision will be entered under Rule 50.
1. The majority stockholders of the petitioner, which was engaged in the business of furnishing supplies, materials and a training base for the Civil Air Patrol, organized a partnership which took over the petitioner's operating activities. Held, the respondent erred in refusing to recognize the partnership for tax…
2Cases cited11 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
- Astor Holding Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1943
- Commissioner of Internal Revenue v. LyonCourt of Appeals for the Ninth Circuit · 1938
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