Beels v. Commissioner
United States Tax Court
1. Partnership. - Petitioner purchased a bar business for $10,000 taking title as sole proprietor. He derived the purchase price from savings, from funds borrowed by his wife and given by her to him, and from other funds borrowed from acquaintances. He applied for a liquor license, executed bond required by law, and executed application for approval of city authorities as sole proprietor. The wife aided in the operation of the bar in the capacity of an employee.
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1. Partnership. - Petitioner purchased a bar business for $10,000 taking title as sole proprietor. He derived the purchase price from savings, from funds borrowed by his wife and given by her to him, and from other funds borrowed from acquaintances. He applied for a liquor license, executed bond required by law, and executed application for approval of city authorities as sole proprietor. The wife aided in the operation of the bar in the capacity of an employee. Wife had no control over income or disbursements. She had no control over proceeds of sale. Held: No partnership existed between…
1Opinion of the Court
Raymond F. Beels v. Commissioner.
Beels v. Commissioner
Docket No. 31476.
United States Tax Court
1953 Tax Ct. Memo LEXIS 383; 12 T.C.M. (CCH) 101; T.C.M. (RIA) 53039;
February 9, 1953
1. Partnership. - Petitioner purchased a bar business for $10,000 taking title as sole proprietor. He derived the purchase price from savings, from funds borrowed by his wife and given by her to him, and from other funds borrowed from acquaintances. He applied for a liquor license, executed bond required by law, and executed application for approval of city authorities as sole proprietor. The wife aided in the…
2Cases cited4 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Pittman v. CommissionerUnited States Tax Court · 1950
- Fox v. Liquor Control CommissionMichigan Supreme Court · 1947
- Dzencol v. Liquor Control CommissionMichigan Supreme Court · 1948