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17 B.T.A. 1064

Pritchett v. Commissioner

United States Board of Tax Appeals

Decided October 25, 1929

United States Board of Tax Appeals · decided 1929-10-25

Held, that the agreement in evidence created an association taxable as a corporation under the provisions of the Revenue Act of 1924. Held: that the agreement in evidence created an association taxable as a corporation under the provisions of the Revenue Act of 1924. J. W. Pritchett et al., Trustees for Hillsboro Court Syndicate,17 B.T.A. 1056.

Cited by 1 later decisions — most recently September 1931

Relies on Pritchett v. Commissioner

Good law ✅— No negative treatment on recordhow we know

Decided 1929-10-25

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¶1*1071OPINION.

Trammell:

¶2The issue in this case is whether the Peabody Court Syndicate, created by the agreement set out in our findings of fact above, is an “association” taxable as a corporation, within the meaning of the Revenue Act of 1924, as determined by the respondent, or whether it is a trust and taxable only as such, as contended by the petitioners.

¶3This same question was before us in the companion case of J. W. Pritchett et al., Trustees for Hillsboro Court Syndicate, 17 B. T. A. 1056, decided this date, wherein we held that the syndicate, acting through its trustees the petitioners herein, was actively engaged in carrying on a business enterprise for profit, and that it was therefore an “ association ” taxable as a corporation under the provisions of the statute. On authority of that decision, the determination of the respondent in this proceeding is approved.

¶4Judgment will be entered for the respondent.

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