Boyt v. Commissioner
United States Tax Court
1. Deduction -- Salary of Employee. -- Amount allowed by respondent sustained, upon failure to show extent or value of services rendered. 2. Partnership. -- Held, that three wives became bona fide partners in a general partnership with their respective husbands and several other persons. 3. Trusts -- Share of Partnership Net Income. -- Certain members of a general partnership made transfers in trust by gifts of percentage interests in the partnership.
Read the full summary
1. Deduction -- Salary of Employee. -- Amount allowed by respondent sustained, upon failure to show extent or value of services rendered. 2. Partnership. -- Held, that three wives became bona fide partners in a general partnership with their respective husbands and several other persons. 3. Trusts -- Share of Partnership Net Income. -- Certain members of a general partnership made transfers in trust by gifts of percentage interests in the partnership. The trusts were neither partners nor subpartners or joint venturers with the respective grantors. Each grantor retained dominion and control…
1Opinion of the Court
OPINION.
Tietjens, Judge:
In the determination of the deficiencies involved in these proceedings, the respondent has recognized the Limited Partnership as a separate venture or enterprise the net income of which was distributable in certain proportions to the limited partner Glen Herrick and to the general partner Boyt Partnership, respectively. No issue has been raised with respect thereto or Boyt Partnership’s income from that source. However, the existence of the Limited Partnership and its prospective profits from war contracts and the dissolution of the Boyt Corporation and the…
2Cases cited5 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. TowerSupreme Court of the United States · 1946
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Rupple v. KuhlCourt of Appeals for the Seventh Circuit · 1949
- Klein v. CommissionerUnited States Tax Court · 1952
3Cited by1 opinion
- Boyt v. CommissionerUnited States Tax Court · 1952