De Korse v. Commissioner
United States Tax Court
During 1939 and 1940 and until February 28, 1941, petitioners operated a tool and die manufacturing business under corporate form. On that date they dissolved the corporation and had the assets transferred to an alleged newly formed partnership composed of themselves and their wives and the minor son of petitioner Koppy. They each purportedly made gifts to their wives, and Koppy to his minor son, of a portion of their interests in the assets.
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During 1939 and 1940 and until February 28, 1941, petitioners operated a tool and die manufacturing business under corporate form. On that date they dissolved the corporation and had the assets transferred to an alleged newly formed partnership composed of themselves and their wives and the minor son of petitioner Koppy. They each purportedly made gifts to their wives, and Koppy to his minor son, of a portion of their interests in the assets. Held, that the wives and minor son were not bona fide partners in the business and that all of the income from the business for 1941 is taxable to…
1Opinion of the Court
Jacob DeKorse, Petitioner, v. Commissioner of Internal Revenue, Respondent. Louis Koppy, Petitioner, v. Commissioner of Internal Revenue, Respondent
De Korse v. Commissioner
Docket Nos. 2116, 2117
United States Tax Court
5 T.C. 94; 1945 U.S. Tax Ct. LEXIS 160;
May 22, 1945, Promulgated
Decisions will be entered under Rule 50.
During 1939 and 1940 and until February 28, 1941, petitioners operated a tool and die manufacturing business under corporate form. On that date they dissolved the corporation and had the assets transferred to an alleged newly formed partnership composed of themselves and their…
Also in this document: Dissent.
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
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