Harris v. Commissioner
United States Tax Court
1. Petitioners are copartners, carrying on a manufacturing business under the name of Union Manufacturing Co. They have two children. Each owns an undivided one-half interest in the business and is entitled to receive one-half of the profits each year. As of January 1, 1943, each petitioner purportedly gave an undivided, one-sixteenth interest in the business to each child.
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1. Petitioners are copartners, carrying on a manufacturing business under the name of Union Manufacturing Co. They have two children. Each owns an undivided one-half interest in the business and is entitled to receive one-half of the profits each year. As of January 1, 1943, each petitioner purportedly gave an undivided, one-sixteenth interest in the business to each child. Neither child contributed any capital originating with himself, and during 1943 neither child performed any services in the business. Under the facts, held, that petitioners did not create a new and bona fide partnership…
1Opinion of the Court
Anna Harris, Petitioner, v. Commissioner of Internal Revenue, Respondent. Morris Harris, Petitioner, v. Commissioner of Internal Revenue, Respondent
Harris v. Commissioner
Docket Nos. 12984, 12985
United States Tax Court
10 T.C. 818; 1948 U.S. Tax Ct. LEXIS 194;
May 12, 1948, Promulgated
Decisions will be entered for the respondent.
1. Petitioners are copartners, carrying on a manufacturing business under the name of Union Manufacturing Co. They have two children. Each owns an undivided one-half interest in the business and is entitled to receive one-half of the profits each year. As of January 1,…
2Cases cited6 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lowry v. CommissionerUnited States Tax Court · 1944
- De Korse v. CommissionerUnited States Tax Court · 1945
- Mauldin v. CommissionerUnited States Tax Court · 1945
- Harris v. CommissionerUnited States Tax Court · 1948
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