Manuel v. Commissioner
United States Tax Court
Petitioner's husband died intestate in 1966. Upon his death, the community property of the couple passed to petitioner. She received an undivided one-half interest in the property, and ownership and possession of the usufruct (similar to a life estate) of the other undivided one-half interest.Subject to the usufruct, each of the four children received an undivided one-fourth interest in their father's share of the community property.
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Petitioner's husband died intestate in 1966. Upon his death, the community property of the couple passed to petitioner. She received an undivided one-half interest in the property, and ownership and possession of the usufruct (similar to a life estate) of the other undivided one-half interest.Subject to the usufruct, each of the four children received an undivided one-fourth interest in their father's share of the community property. The community property consisted for the most part of an 800-acre farm. Held, for the years in question, a family partnership did not exist for Federal income…
1Opinion of the Court
LIZZIE M. MANUEL, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Manuel v. Commissioner
Docket Nos. 12840-80, 15335-80, 15336-80, 2320-81.
United States Tax Court
T.C. Memo 1983-138; 1983 Tax Ct. Memo LEXIS 647; 45 T.C.M. (CCH) 981; T.C.M. (RIA) 83138;
March 16, 1983.
Petitioner's husband died intestate in 1966. Upon his death, the community property of the couple passed to petitioner. She received an undivided one-half interest in the property, and ownership and possession of the usufruct (similar to a life estate) of the other undivided one-half interest.Subject to the…
2Cases cited11 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Bayou Verret Land Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1971
- Messer v. CommissionerUnited States Tax Court · 1969
- Krause v. CommissionerUnited States Tax Court · 1972
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Tifd Iii-E, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2012