Roselle v. Commissioner
United States Tax Court
During 1972, a partnership provided management services to three corporations and engaged in other activities in which capital was a material income-producing factor. Held, for purposes of sec. 1348, I.R.C. 1954, the management services provided by the partnership constituted a separate trade or business and capital was not a material income-producing factor in that business. Held further, the management services income constitutes earned income under sec. 1348, I.R.C. 1954.
1Opinion of the Court
CRESCENT J. ROSELLE AND DOROTHY ROSELLE, LOUIS P. ROSELLE AND MARY G. ROSELLE, ARTHUR ROSELLE AND JOSEPHINE ROSELLE, JOSEPH C. ROSELLE AND ANITA ROSELLE, ESTATE OF PETER ROSELLE, DECEASED, VERNOICA ROSELLE, EXECUTRIX, AND VERONICA ROSELLE, Petitioners v COMMISSIONER OF INTERNAL REVENUE, Respondent
Roselle v. Commissioner
Docket No. 7902-76.
United States Tax Court
T.C. Memo 1981-394; 1981 Tax Ct. Memo LEXIS 346; 42 T.C.M. (CCH) 539; T.C.M. (RIA) 81394;
July 30, 1981.
During 1972, a partnership provided management services to three corporations and engaged in other activities in which capital was a…
2Cases cited14 opinions
- Davis v. CommissionerUnited States Tax Court · 1976
- United States v. New YorkSupreme Court of the United States · 1942
- Sherman v. CommissionerUnited States Tax Court · 1951
- Rousku v. CommissionerUnited States Tax Court · 1971
- Moore v. CommissionerUnited States Tax Court · 1979
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