Legal Opinion
J.N. Ledbetter and R.W. Ledbetter v. United States
Court of Appeals for the Eleventh Circuit
Decided June 27, 1986No. 85-5933PublishedCited by 1 opinion
1Opinion of the Court
TUTTLE, Senior Circuit Judge:
This appeal tests the validity of an Internal Revenue Service regulation which, for the tax years 1973, 1974, and 1975, limited the amount of income received by taxpayer from his partnership that could be treated as “earned income.” As stated by the Court of Appeals for the Second Circuit in an identical case:
This appeal involves the narrow question whether guaranteed partnership income, viewed as salary by Internal Revenue Code § 707(c), is subject to the limits on taxation of earned income imposed by Code Section 1348 [and Treas.Reg. 1.1348-3(a)(3)(i) ] for…
2Cases cited5 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Daniel S. Kampel and Clarisse Kampel v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
- Kampel v. CommissionerUnited States Tax Court · 1979
- William P. Zahler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
3Cited by1 opinion
- Michael G. Jolin and Susan P. Jolin v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989