Jurs

Jurs v. Commissioner of Internal Revenue

Good Law
147 F.2d 805·33 A.F.T.R. (P-H) 742·1945 U.S. App. LEXIS 4365
United States Court of Appeals for the Ninth CircuitFebruary 12, 1945No. 10734California332 words

Opinion

Lead Opinion

Bone, J.

These are petitions to review decisions of the Tax Court sustaining the assessment of deficiencies in income taxes of four petitioning taxpayers for the year 1940.

On July 8, 1942, the Commissioner of Internal Revenue mailed a notice of defi *806 ciency to the four taxpayers above named, asserting a claimed deficiency in the income taxes of each of them for the calendar year of 1940. The facts in each of these claimed deficiencies stem from the operations of a copartnership composed of the four taxpayers, petitioners herein. On October 5, 1942, and within ninety days after the mailing of the said notices of deficiency, the taxpayers filed petitions with the Tax Court for a re-determination of the deficiencies under the provisions of Section 272 of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code § 272. A formal hearing on these petitions was had before the Tax Court, and that Court entered findings of fact and a formal opinion on August 20, 1943. On October 27, 1943, the taxpayers filed a motion for further or additional findings of fact which was denied by order of the Tax Court on October 28, 1943. The final decision of the Tax Court determining deficiencies in tax as found…

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