Friedman v. Commissioner
United States Tax Court
1. Transfer of interest in established business to minor children contributing no new capital nor any services, held not sufficient to create valid partnership therein for income tax purposes, so as to relieve from tax petitioner-fathers, whose personal services were major income-producing factor, notwithstanding that some services were rendered to business by an employee, selected as "nominee" for the children by their legal guardians. 2. Partnership interest originating in…
Read the full summary
1. Transfer of interest in established business to minor children contributing no new capital nor any services, held not sufficient to create valid partnership therein for income tax purposes, so as to relieve from tax petitioner-fathers, whose personal services were major income-producing factor, notwithstanding that some services were rendered to business by an employee, selected as "nominee" for the children by their legal guardians. 2. Partnership interest originating in capital owned prior to marriage, held transformed into community property by agreement of spouses. 3. Interests in…
1Opinion of the Court
Samuel Friedman, Petitioner, et al., 1 v. Commissioner of Internal Revenue, Respondent
Friedman v. Commissioner
Docket Nos. 10856, 10857, 10858, 10859, 10860, 10861, 10862, 10863
United States Tax Court
10 T.C. 1145; 1948 U.S. Tax Ct. LEXIS 151;
June 23, 1948, Promulgated
Decisions will be entered under Rule 50.
1. Transfer of interest in established business to minor children contributing no new capital nor any services, held not sufficient to create valid partnership therein for income tax purposes, so as to relieve from tax petitioner-fathers, whose personal services were major income-producing…
2Cases cited2 opinions
- In re RalphSupreme Court of Iowa · 1839
- Friedman v. CommissionerUnited States Tax Court · 1948