Legal Opinion

Canfield v. Commissioner

United States Tax Court

Decided October 11, 1946No. Docket No. 5864Published

1. Allocation of income between husband and wife determined, where both contributed capital and the husband contributed services to a business enterprise. 2. Held, imposition of negligence penalty not justified.

1Opinion of the Court

Claire L. Canfield, Petitioner, v. Commissioner of Internal Revenue, Respondent

Canfield v. Commissioner

Docket No. 5864

United States Tax Court

7 T.C. 944; 1946 U.S. Tax Ct. LEXIS 62;

October 11, 1946, Promulgated

Decision will be entered under Rule 50.

1. Allocation of income between husband and wife determined, where both contributed capital and the husband contributed services to a business enterprise.

2. Held, imposition of negligence penalty not justified.

R. M. O'Hara, Esq., and Harry A. Smith, C. P. A., for the petitioner.

Lawrence R. Bloomenthal, Esq., for the respondent.

Van Fossan, Judge.…

Also in this document: Dissent.

2Cases cited4 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Drennen v. London Assurance Co.Supreme Court of the United States · 1885
  3. Paul v. CullumSupreme Court of the United States · 1889
  4. Canfield v. CommissionerUnited States Tax Court · 1946

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API