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The petitioners bought several parcels of land together and later sold some of the parcels, realizing a profit. The Commissioner of Internal Revenue assessed them for corporate income tax, arguing their relationship constituted an unregistered partnership. The Court of Tax Appeals affirmed this. However, the Supreme Court ruled there was no partnership formed. Unlike a previous case where numerous frequent land transactions indicated an intent to engage in business, the petitioners

Author

Robert Espina

Language

EN