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GIANT AUTO PARTS, LTD. v. COMMISSIONER

Docket No. 16290.

14 T.C. 579 (1950)

GIANT AUTO PARTS, LTD., BY JACOB FROST, JULIUS FROST, MILTON FROST, IRVIN FROST, SEYMORE FROST, AND MARIE FROST LEVIN, FORMERLY DOING BUSINESS AS GIANT AUTO PARTS, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 12, 1950.

Attorney(s) appearing for the Case

Tress E. Pittenger, Jr., Esq., for the petitioner.

Robert C. Whitley, Esq., for the respondent.

SUPPLEMENTAL OPINION.

ARUNDELL, Judge:

We have previously held, in our opinion promulgated September 15, 1949, and published at 13 T.C. 307, that during the taxable years 1942, 1943, and 1944 the petitioner's organization and manner of operation were more closely akin to that of a corporation than a partnership, and for that reason the petitioner was an association taxable as a corporation within the purview of section...

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