# Carnie-Goudie Mfg. Co. v. Commissioner

> United States Board of Tax Appeals · January 21, 1930 · 18 B.T.A. 893

URL: https://www.frixlaw.com/law-library/cases/4490153

## Case

- **Full name:** CARNIE-GOUDIE MANUFACTURING CO., <emphasis typestyle="it">v.</emphasis> COMMISSIONER OF INTERNAL REVENUE, <sup id="fnr_fnote1"><a href="fn_fnote1" id="">1</a></sup>
- **Court:** United States Board of Tax Appeals
- **Decided:** January 21, 1930
- **Citations:** 18 B.T.A. 893; 1930 BTA LEXIS 2576
- **Precedential status:** Published
- **Opinion:** Dissent by Tkammell
- **Judges:** Lansdon, Tkammell
- **Cited by:** 8 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4490153

## Opinion text

Tkammell,
dissenting: In my opinion, the evidence shows that the general retail store was in fact not a partnership. It may well be that under the facts the individuals could in a proper case have been held liable as partners, but this fact is not material. They must have been so in fact if the tax liability is to be determined on that basis. In my opinion, the evidence shows that in fact the individuals did not operate as a separate business.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4490153. Public record. Not legal advice.