Questão jurídica principal
Whether a partner in a simple partnership may deduct from taxable income a share of the partnership losses exceeding his ownership interest.
Decisão extraída
No. The deductible share of the partnership’s losses is limited to the taxpayer’s participation share in the simple partnership.
Fundamentação extraída
The court held that income-tax deduction follows the taxpayer’s proportionate economic interest in the simple partnership; losses cannot be allocated beyond that share.