Baltimore v. Commissioner
United States Tax Court
In early 1949, petitioner was employed in the butter and egg business at a total remuneration of $175 per week. Three persons wishing to commence such a business persuaded him to leave his employment to manage the new enterprise. It was agreed that petitioner would operate the business but make no capital investment, and would receive a salary of $125 per week, plus an equal share in the enterprise.
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In early 1949, petitioner was employed in the butter and egg business at a total remuneration of $175 per week. Three persons wishing to commence such a business persuaded him to leave his employment to manage the new enterprise. It was agreed that petitioner would operate the business but make no capital investment, and would receive a salary of $125 per week, plus an equal share in the enterprise. A corporation was formed, and each of the other three persons invested $10,000. Soon thereafter, a need for additional capital became apparent, and a fourth individual invested $10,000. Petitioner…
1Opinion of the Court
Stuart L. Baltimore and Glennis M. Baltimore v. Commissioner.
Baltimore v. Commissioner
Docket No. 62629.
United States Tax Court
T.C. Memo 1958-78; 1958 Tax Ct. Memo LEXIS 150; 17 T.C.M. (CCH) 388; T.C.M. (RIA) 58078;
April 30, 1958
In early 1949, petitioner was employed in the butter and egg business at a total remuneration of $175 per week. Three persons wishing to commence such a business persuaded him to leave his employment to manage the new enterprise. It was agreed that petitioner would operate the business but make no capital investment, and would receive a salary of $125 per week, plus an…
2Cases cited11 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Appeal of Estate of DalyUnited States Board of Tax Appeals · 1926
- Lammerding v. CommissionerUnited States Board of Tax Appeals · 1939
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