¶1dissenting: It is inconceivable to me that Congress ever intended to permit deductions of the type approved herein, notwithstanding the elaborate effort to cast them in the form of business expenses, a mere device without economic reality or substance regardless of whether the transactions may or may not properly be described as “bona fide.”
21 T.C. 794
Felix v. Commissioner
Decided February 26, 1954
United States Tax Court · decided 1954-02-26
1. In determining deficiencies against petitioners for the taxable period July 26, 1945, to February 28, 1946, respondent refused to recognize Ernest Felix and his wife, Mary Felix, as bona fide… Held: Ernest Felix and Mary Felix were bona fide partners during the taxable period involved, and the partnership income is taxable to the four partners in accordance with their agreement. 2.
Good law ✅— No negative treatment on recordhow we know
Decisions will be entered under Rule 50 · Decided 1954-02-26
How this case has been cited
Cited by 16 later decisions — most recently July 1980
1 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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