Appeal of Bessell

Board of Tax Appeals

Appeal of Bessell

3 B.T.A. 567

CourtUnited States Board of Tax Appeals

DecidedFebruary 3, 1926

DocketDocket No. 4971

StatusPublished

Cited by1 cases

This text of 3 B.T.A. 567 (Appeal of Bessell) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of Bessell, 3 B.T.A. 567 (bta 1926).

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Opinion

[568]*568OPINION.

Phillips

: It is apparent from the findings of fact that the Commissioner has charged taxpayer with income which is properly chargeable to the other members of the partnership. The senior members of the partnership had originally contributed capital in the business which had been impaired during the continuance of the previous partnership. One of the conditions of the new partnership was that all profits in excess of salaries should be credited to such senior partners until the original capital invested was restored, and this disposition was made of the profits for 1919.

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[568]*568OPINION.

Phillips

: It is apparent from the findings of fact that the Commissioner has charged taxpayer with income which is properly chargeable to the other members of the partnership. The senior members of the partnership had originally contributed capital in the business which had been impaired during the continuance of the previous partnership. One of the conditions of the new partnership was that all profits in excess of salaries should be credited to such senior partners until the original capital invested was restored, and this disposition was made of the profits for 1919.

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Bluebook (online)

3 B.T.A. 567, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-bessell-bta-1926.

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