Louis B. Ginsberg and Grace Ginsberg v. Commissioner of Internal Revenue

PHILLIPS, Chief Judge.

Mr. and Mrs. Louis .B. Ginsberg (taxpayers) appeal from a decision of the United States Tax Court upholding the Commissioner’s determination of federal income tax deficiencies in the aggregate amount of $29,049.52 for the taxable years 1966 through 1968. We affirm.

For a comprehensive statement of the facts, reference is made to the Tax Court opinion prepared by Judge Theodore Tannenwald, Jr., 32 CCH Tax Ct. Mem. 1019 (1973).

The question before us is whether a trust created by Mr. Ginsberg for the benefit of his minor daughter is a bona fide partner in the family business…