Ketter v. Commissioner
United States Tax Court
P operated an accounting practice as a sole proprietorship. During December 1968, P established eight trusts for the benefit of his six children and college alma mater. He transferred to these trusts work in progress of his accounting proprietorship, and employment contracts covering his employees.
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P operated an accounting practice as a sole proprietorship. During December 1968, P established eight trusts for the benefit of his six children and college alma mater. He transferred to these trusts work in progress of his accounting proprietorship, and employment contracts covering his employees. The trusts formed a partnership to provide accounting services for accountants, transferring the work in progress and the employment contracts to the partnership, and hired P as manager. The partnership performed those services under P's direction with the employees encompassed by the employment…
1Opinion of the Court
Wilbur,’ Judge:
Respondent determined deficiencies in petitioners’ Federal income tax as follows:
Year Deficiency
1968.$6,842.90
1969. 3,403.89
1970. 254.57
Total 10,501.36
These deficiencies resulted from respondent’s conclusion that a partnership between eight trusts established by petitioner, Melvin P. Ketter, should not be recognized for Federal income tax purposes, and that the partnership income was taxable to him. The issue presented for our determination is whether the partnership should be recognized for Federal income tax purposes under section 704(e).1
FINDINGS OF FACT
Some of the facts…
2Cases cited18 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Max Kuney, Jr., and Constance K. Kuney, His Wife Max J. Kuney, Sr., Olive R. Kuney v. William E. Frank, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Krause v. CommissionerUnited States Tax Court · 1972
- Adolph K. Krause and Janet S. Krause v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1974
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3Cited by16 opinions
- Penrod v. CommissionerUnited States Tax Court · 1987
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- Van Kalker v. CommissionerUnited States Tax Court · 1983
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