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