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  • Frederick E. Anderson v. Commissioner of Internal Revenue, 185 F.2d 1021, 2d Cir. (1951)

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    1) The petitioner sought recognition for tax purposes of a partnership between himself and his wife as the sole partners. 2) The Tax Court denied recognition of the partnership and redetermined deficiencies in the petitioner's income taxes for 1943, 1944 and 1945. 3) The Court of Appeals affirmed the Tax Court's decisions on the authority of an earlier case that set a precedent for denying recognition of partnerships between spouses for tax purposes.

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    Filed: 1951-01-24 Precedential Status: Precedential Citations: 185 F.2d 1021 Docket: 21757

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    1) The petitioner sought recognition for tax purposes of a partnership between himself and his wife as the sole partners. 2) The Tax Court denied recognition of the partnership and redetermined deficiencies in the petitioner's income taxes for 1943, 1944 and 1945. 3) The Court of Appeals affirmed the Tax Court's decisions on the authority of an earlier case that set a precedent for denying recognition of partnerships between spouses for tax purposes.

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    Frederick E. Anderson v. Commissioner of Internal Revenue, 185 F.2d 1021, 2d Cir. (1951)

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    1) The petitioner sought recognition for tax purposes of a partnership between himself and his wife as the sole partners. 2) The Tax Court denied recognition of the partnership and redetermined deficiencies in the petitioner's income taxes for 1943, 1944 and 1945. 3) The Court of Appeals affirmed the Tax Court's decisions on the authority of an earlier case that set a precedent for denying recognition of partnerships between spouses for tax purposes.

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    of 1

    185 F.

    2d 1021

    Frederick E. ANDERSON, Petitioner,


    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 122.
    No. 123.
    Docket 21756.
    Docket 21757.

    United States Court of Appeals Second Circuit.


    Argued January 10, 1951.
    Decided January 24, 1951.

    Petitions to review two decisions of the Tax Court consolidated for


    hearing, redetermining deficiencies in the income taxes of the petitioner
    for the years 1943, 1944 and 1945. The petitioner sought, and was denied,
    recognition for tax purposes of a partnership in which he and his wife
    were the sole partners.
    Kirlin, Campbell, Hickox & Keating, New York City, H. Maurice
    Fridlund, Earl Q. Kullman, New York City, William A. Sheehan,
    Brooklyn, N. Y., of counsel, for petitioner.
    Charles Oliphant, Washington, D. C., Theron Lamar Caudle, Asst. Atty.
    Gen., Ellis N. Slack, Robert N. Anderson, and Louise Foster, Sp. Assts. to
    Atty. Gen., for respondent.
    Before CHASE, CLARK and FRANK, Circuit Judges.
    PER CURIAM.

    Decisions affirmed on the authority of Morrison v. Commissioner of Internal


    Revenue, 2 Cir., 177 F.2d 351.

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