Schmitz v. Commissioner
United States Tax Court
A father and two sons were equal partners in a cattle ranch. They orally agreed that upon the father's death, the sons would pay their mother 20 percent of the gross receipts from steer sales in order to provide her with support. Held, the payments in question were made pursuant to this agreement and represent the mother's distributive share of the partnership receipts.
1Opinion of the Court
RAYMOND W. SCHMITZ AND JEANNETTE SCHMITZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
STEPHEN SCHMITZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Schmitz v. Commissioner
Docket Nos. 1066-76, 1067-76.
United States Tax Court
T.C. Memo 1978-317; 1978 Tax Ct. Memo LEXIS 194; 37 T.C.M. (CCH) 1323; T.C.M. (RIA) 78317;
August 15, 1978, Filed
A father and two sons were equal partners in a cattle ranch. They orally agreed that upon the father's death, the sons would pay their mother 20 percent of the gross receipts from steer sales in order to provide her with support. Held,…
2Cases cited3 opinions
- Balafas v. BalafasSupreme Court of Minnesota · 1962
- Stearns v. Inhabitants of BrooklineMassachusetts Supreme Judicial Court · 1914
- Sorokach v. TrusewichSupreme Court of New Jersey · 1953
3Cited by1 opinion
- Boca Investerings Partnership v. United StatesDistrict Court, District of Columbia · 2001