![]() Near the end of 1938 he withdrew and Cleo and Leo as equal partners in a partnership, sometimes hereinafter referred to as Stater Brothers Partnership, continued the operation of the two markets.Ĭleo and Leo each joined the enlisted reserve corps of the United States Army in 1942 and were assigned to inactive duty. Stater, a brother of Cleo and Leo, orally joined the partnership as an equal partner. Stater, who are brothers, orally joined together as equal partners for the purpose of operating a retail food market in Yucaipa, California, under the name of "Stater Bros."Ībout January 1, 1938, the partnership acquired a second retail food market which was situated in Colton, California, and Lavoy R. They filed their Federal joint income tax returns for the years 1953 through 1958 with the director in Los Angeles, California. Stater are husband and wife with residence in San Bernardino, California. Stater are husband and wife with residence in Corona del Mar, California. The Federal income tax returns of the corporate petitioners herein for the taxable years with respect to which the respondent has made determinations of deficiencies in their income tax liability were filed with the director in Los Angeles, California. Some of the facts have been stipulated and are found accordingly. As a consequence, only issues (1) and (2) remain for determination. The respondent made the foregoing contested determinations in the alternative and on brief concedes error as to the determination involved in issue (3). Stater were equal partners, (2) that the respective petitioner corporations for their respective taxable years were entitled only to a fraction of one surtax exemption and, for the applicable years, only to a like fraction of one minimum excess profits credit and that in the aggregate all of the petitioner corporations were entitled to only one such exemption and for applicable years one such credit, and (3) that the petitioner corporations together with Stater Brothers Partnership constituted an association taxable as a corporation for the calendar years in which the fiscal years of the corporations ended. Issues presented by the pleadings are the correctness of the respondent's action in determining (1) that the income reported by the petitioner corporations for their respective taxable years as having been derived from joint ventures with retail food market managers was includible in the income of Stater Brothers Partnership in which petitioners Cleo M. East Riverside | 12/31/54 237,184.42Īn association taxable as a corporation | The respondent has determined deficiencies in the income tax of the petitioners as follows:
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