Bellamy v. Commissioner
United States Tax Court
In 1943, when they were both in the armed service, petitioner and his son, then 18 years old and without business experience, executed a purported partnership agreement covering the ownership and operation of a wholesale drug business which petitioner, as sole owner, had conducted for more than 20 years. Pursuant to the agreement, petitioner was to have a 51 per cent interest and the son 49 per cent.
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In 1943, when they were both in the armed service, petitioner and his son, then 18 years old and without business experience, executed a purported partnership agreement covering the ownership and operation of a wholesale drug business which petitioner, as sole owner, had conducted for more than 20 years. Pursuant to the agreement, petitioner was to have a 51 per cent interest and the son 49 per cent. A short time later petitioner had the son give him a demand note in amount of 49 per cent of the net book value of the business, although he did not regard the note as being equal in amount to a…
1Opinion of the Court
Hargrove Bellamy, Petitioner, v. Commissioner of Internal Revenue, Respondent
Bellamy v. Commissioner
Docket No. 20651
United States Tax Court
14 T.C. 867; 1950 U.S. Tax Ct. LEXIS 196;
May 18, 1950, Promulgated
Decision will be entered under Rule 50.
In 1943, when they were both in the armed service, petitioner and his son, then 18 years old and without business experience, executed a purported partnership agreement covering the ownership and operation of a wholesale drug business which petitioner, as sole owner, had conducted for more than 20 years. Pursuant to the agreement, petitioner was to have…
2Cases cited1 opinion
- Bellamy v. CommissionerUnited States Tax Court · 1950