Le Sage v. Commissioner of Internal Revenue

LEE, Circuit Judge.

This case presents the question of the bona fides and realities for tax purposes of a family-partnership arrangement between father and daughter, and also the question of the actual date of sale of a partnership interest in another and unrelated enterprise. The petitioners, Robert S. and Julia LeSage, residents of the State of Texas, are husband and wife, the latter being a party only because all net income during the calendar years 1942 and 1943, the years involved in this litigation, was community income.

Dealing first with the date of sale of Robert S-. LeSage’s interest…