Legal Opinion

Hiram W. Evans v. Commissioner

United States Tax Court

Decided April 30, 1946No. Docket Nos. 3313, 3314Unpublished

Petitioner organized, financed, managed and controlled successively three different partnerships of which his wife, three children, a brother-in-law and his secretary were named as partners. The partnerships also operated in part under certain trade names. The business of the partnerships was largely that of sales agent for road building materials on a commission basis. Held, under the facts, petitioner is taxable on all of the income of the partnerships.

1Opinion of the Court

Hiram W. Evans v. Commissioner. Hiram Wesley Evans v. Commissioner.

Hiram W. Evans v. Commissioner

Docket Nos. 3313, 3314.

United States Tax Court

1946 Tax Ct. Memo LEXIS 200; 5 T.C.M. (CCH) 336; T.C.M. (RIA) 46102;

April 30, 1946

Petitioner organized, financed, managed and controlled successively three different partnerships of which his wife, three children, a brother-in-law and his secretary were named as partners. The partnerships also operated in part under certain trade names. The business of the partnerships was largely that of sales agent for road building materials on a commission basis.…

2Cases cited9 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Durden v. CommissionerUnited States Tax Court · 1944
  4. Johnston v. CommissionerUnited States Tax Court · 1944
  5. Williams v. CommissionerUnited States Tax Court · 1944

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