Parker v. Commissioner
United States Tax Court
1. Petitioner and his wife were carrying on a business together as a partnership in the State of Massachusetts during each of the taxable years. The nature of the business was the sale of machine tools on commission by contact with customers and sale of tools and machine parts out of inventory stock kept in a room in the home of petitioner and his wife.
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1. Petitioner and his wife were carrying on a business together as a partnership in the State of Massachusetts during each of the taxable years. The nature of the business was the sale of machine tools on commission by contact with customers and sale of tools and machine parts out of inventory stock kept in a room in the home of petitioner and his wife. Petitioner traveled most of the time and sold machine tools on commission for the partnership and his wife took care of the orders that came in for tools and machine parts out of stock and other orders over the telephone. She also attended to…
1Opinion of the Court
OPINION.
Black, Judge:
The first question presented for our decision in the instant-case is whether a partnership existed between the petitioner and his -Wife, residents of the Commonwealth of Massachusetts, during the years 1940 and 1941, within the meaning of the Federal statutes. The applicable statutes are printed in the margin.1 We think the question must be answered in the affirmative and that the partnership and the members thereof complied in every respect, in both the taxable years, with the statutes printed in the margin. Respondent in his brief lays great stress on the fact that…
2Cases cited6 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Zukaitis v. CommissionerUnited States Tax Court · 1944
1 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Goodman v. CommissionerUnited States Tax Court · 1946
- Felix v. CommissionerUnited States Tax Court · 1949
- Kuzmick v. CommissionerUnited States Tax Court · 1948
- Forsythe v. CommissionerUnited States Tax Court · 1948
- Lang v. CommissionerUnited States Tax Court · 1946
20 more not listed; retrieve them via the Exa API.