Jennings v. Commissioner
United States Tax Court
For 25 years prior to 1942 petitioner operated his own business of selling railway parts and supplies. He, his wife, and his adult son executed a written partnership agreement, to be effective January 1, 1942. Held, petitioner's adult son was a bona fide partner because he performed vital additional services during 1942 and 1943 and his share of partnership net income is not taxable to petitioner; held, further, that petitioner is not taxable on the share of partnership…
Read the full summary
For 25 years prior to 1942 petitioner operated his own business of selling railway parts and supplies. He, his wife, and his adult son executed a written partnership agreement, to be effective January 1, 1942. Held, petitioner's adult son was a bona fide partner because he performed vital additional services during 1942 and 1943 and his share of partnership net income is not taxable to petitioner; held, further, that petitioner is not taxable on the share of partnership profits allocated to his wife in proportion to their respective capital contributions after deducting the reasonable value…
1Opinion of the Court
David L. Jennings, Petitioner, v. Commissioner of Internal Revenue, Respondent
Jennings v. Commissioner
Docket No. 11972
United States Tax Court
10 T.C. 505; 1948 U.S. Tax Ct. LEXIS 237;
March 23, 1948, Promulgated
Decision will be entered under Rule 50.
For 25 years prior to 1942 petitioner operated his own business of selling railway parts and supplies. He, his wife, and his adult son executed a written partnership agreement, to be effective January 1, 1942. Held, petitioner's adult son was a bona fide partner because he performed vital additional services during 1942 and 1943 and his share of…
2Cases cited1 opinion
- Jennings v. CommissionerUnited States Tax Court · 1948