Legal Opinion

Acuff v. Commissioner

United States Tax Court

Decided October 31, 1960No. Docket No. 70173PublishedCited by 18 opinions

In January 1952 petitioners entered into a trust agreement with Roy Acuff as trustee transferring an undivided one-third interest in a business conducted by Roy Acuff as a sole proprietorship, and an undivided one-third interest in a one-half interest in a music publishing partnership owned by Mildred Acuff, to a trust for the benefit of petitioners' minor son.

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In January 1952 petitioners entered into a trust agreement with Roy Acuff as trustee transferring an undivided one-third interest in a business conducted by Roy Acuff as a sole proprietorship, and an undivided one-third interest in a one-half interest in a music publishing partnership owned by Mildred Acuff, to a trust for the benefit of petitioners' minor son. The trust agreement directed the trustee to enter into a partnership with the two petitioners for the management and operation of the two business interests. Contemporaneously therewith a partnership agreement was entered into between…

1Opinion of the Court

OPINION.

ÜRENnen, Judge:

Respondent determined deficiencies in petitioners’ income tax for the calendar years 1952, 1953, and 1954 in the amounts of $16,547.30, $21,062.84, and $5,790.40, respectively. The deficiencies as determined by respondent result from certain minor adjustments in petitioners’ income, and the inclusion in petitioners’ income for each of the years of all of the income reported by a partnership, Acuff & Acuff, in which the petitioners individually and Roy C. Acuff as trustee of a trust established by petitioners for the benefit of their minor son were purportedly equal…

2Cases cited16 opinions

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Commissioner v. TowerSupreme Court of the United States · 1946
  4. National Licorice Co. v. National Labor Relations BoardSupreme Court of the United States · 1940
  5. Rupple v. KuhlCourt of Appeals for the Seventh Circuit · 1949

11 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Flitcroft v. CommissionerUnited States Tax Court · 1962
  2. Krause v. CommissionerUnited States Tax Court · 1972
  3. Duarte v. CommissionerUnited States Tax Court · 1965
  4. Ketter v. CommissionerUnited States Tax Court · 1978
  5. Horstmier v. CommissionerUnited States Tax Court · 1983

13 more not listed; retrieve them via the Exa API.

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