Legal Opinion

Nathan v. Commissioner

United States Tax Court

Decided May 14, 1943No. Docket Nos. 102726, 102727, 102728, 102730Unpublished

1. On the facts it is held that petitioners' wives, and several trusts created for the benefit of their children, acquired bona fide interests, as limited partners, in a limited partnership of which petitioners were members and which succeeded a former general partnership consisting only of the petitioners. 2. The fact that one of the purposes of the admission of the limited partners was to effect reduction in petitioners' income tax liabilities held not to require taxation…

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1. On the facts it is held that petitioners' wives, and several trusts created for the benefit of their children, acquired bona fide interests, as limited partners, in a limited partnership of which petitioners were members and which succeeded a former general partnership consisting only of the petitioners. 2. The fact that one of the purposes of the admission of the limited partners was to effect reduction in petitioners' income tax liabilities held not to require taxation to them of distributive shares of profits of limited partners where other legitimate purpose existed, and interests of…

1Opinion of the Court

Sidney Nathan v. Commissioner. Louis Grossman v. Commissioner. Arthur Klein v. Commissioner. Edwin Rosenberg v. Commissioner.

Nathan v. Commissioner

Docket Nos. 102726, 102727, 102728, 102730.

United States Tax Court

1943 Tax Ct. Memo LEXIS 302; 2 T.C.M. (CCH) 45; T.C.M. (RIA) 43232;

May 14, 1943

1. On the facts it is held that petitioners' wives, and several trusts created for the benefit of their children, acquired bona fide interests, as limited partners, in a limited partnership of which petitioners were members and which succeeded a former general partnership consisting only of the petitioners.

2Cases cited24 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Helvering v. CliffordSupreme Court of the United States · 1940
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Poe v. SeabornSupreme Court of the United States · 1930
  5. Douglas v. WillcutsSupreme Court of the United States · 1935

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