Legal Opinion

Hartman v. Commissioner

United States Tax Court

Decided October 26, 1964No. Docket Nos. 1873-62, 1874-62, 1249-63, 2470-63PublishedCited by 18 opinions

1. Held, that Shafford Co., which merchandised, distributed, and sold throughout the United States, ceramic ware that was imported into the United States by the corporate petitioner, U.S. Asiatic Co., Inc., was a business separate and distinct from Asiatic. 2. Held, further, that Shafford Co. was a valid partnership, the members of which were petitioner Sanford Hartman and two trusts for his minor children.

1Opinion of the Court

Pierce, Judge:

The Commissioner determined deficiencies in the income taxes of the petitioners as follows:

Sanford H. and Henrietta Hartman

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U.S. Asiatic Co., Inc.

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The cases were consolidated for trial.

Petitioner Sanford Hartman, the sole stockholder of the corporate petitioner, U.S. Asiatic Co., organized in form at least a partnership (Shafford Co.), with himself and two trusts for his minor children as partners, which thereafter principally engaged in merchandising, marketing, and distributing ceramic ware imported into the United States by Asiatic Co. The issues…

2Cases cited6 opinions

  1. Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  2. Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
  3. Miles-Conley Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1949
  4. Miles-Conley Co. v. CommissionerUnited States Tax Court · 1948
  5. Moke Epstein, Inc. v. CommissionerUnited States Tax Court · 1958

1 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
  2. Inter-City Television Film Corp. v. CommissionerUnited States Tax Court · 1964
  3. Ketter v. CommissionerUnited States Tax Court · 1978
  4. Max J. Kuney, Jr., and Constance K. Kuney v. United StatesCourt of Appeals for the Ninth Circuit · 1971
  5. Gettler v. CommissionerUnited States Tax Court · 1975

13 more not listed; retrieve them via the Exa API.

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