Batman v. Commissioner, 189 F.2d 107 (5th Cir. 1951), is a 1951 decision of the United States Court of Appeals for the Fifth Circuit in the area of partnership taxation. It concerned a bid by a Texas Panhandle farmer to convert his farm into a family partnership by transferring some of its assets to his teenaged son. A three-judge panel unanimously affirmed the decision of the United States Tax Court that disallowed this. The Tax Court judge had not found that any of the actions taken to convert the farm into a partnership between father and son were the result of a genuine desire by the young man to be his father's partner. Although he had been doing a fair share of the farm's work, it seemed his father had taken all the steps to make him a partner, against the advice of his banker. The sole reason for the action was found to be a desire by the petitioner to reduce his individual tax liability. Joseph Chappell Hutcheson, Jr., then the circuit's chief judge, wrote for the panel in affirming the Tax Court's holding, although he also left intact some of the refunds it had granted. In a later case, the Tax Court found that a family partnership was formed for some subsequent tax years. While it has not been cited in many later tax cases, its unintentionally humorous title, suggesting a lawsuit between Batman and Commissioner Gordon from the DC Comics franchise, has earned it some notoriety in legal circles. Underlying dispute After spending his teen years working in wheat fields around the country, Ray Batman settled down on his own farm near Perryton, Texas, in 1923. His wife Edith bore a daughter and a son. By 1942 he had done well enough to purchase some of the land he had been renting. Three years later he farmed and ranched 200 head of cattle on over of land near Perryton and in nearby Harper County, Kansas. Batman was impressed by his son, Gerald, who worked hard on the farm on his school vacations and expressed interest in becoming a farmer himself. In either late 1943 or early 1944, he approached his accountant about making Gerald a partner in the farm, even though his son was only 14 at the time. The accountant tried to dissuade him from doing so, saying that the Treasury Department did not have a