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KOPPELMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 10733.

199 F.2d 955 (1952)

Theodore KOPPELMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided December 1, 1952.

Attorney(s) appearing for the Case

Monte Appel, Washington, D. C. (Blair, Körner, Doyle & Appel, Washington, D. C., on the brief), for appellant.

Joseph Goetten, Washington, D. C. (Charles S. Lyon, Asst. Atty. Gen., Ellis N. Slack, Carolyn R. Just, Sp. Assts. to Atty. Gen., on the brief), for appellee.

Before McLAUGHLIN, KALODNER and STALEY, Circuit Judges.

PER CURIAM.

In this family partnership case, the Tax Court rightly recognized that, as far as its validity for income tax purposes was concerned, it was governed by the rule of Commissioner v. Culbertson, 337 U.S. 733, 69 S.Ct. 1210, 93 L.Ed. 1659. So tested the Court found that the agreement in which the trustees of the trust or trusts created by the petitioner were named as a partner was not made in good faith and with a business...

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