Legal Opinion

Neumann v. Commissioner

United States Tax Court

Decided December 16, 1947No. Docket No. 11383Published

1. Profits earned by a wife's operation of a boarding and rooming house in Texas, a community property state, held, derived from the wife's personal services within the meaning of section 811 (e), Internal Revenue Code. 2. The value of a farm purchased in Texas with community funds, comprising profits derived from the surviving wife's personal services, held, includible in the value of the deceased husband's gross estate, with the exception of the interest acquired with such…

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1. Profits earned by a wife's operation of a boarding and rooming house in Texas, a community property state, held, derived from the wife's personal services within the meaning of section 811 (e), Internal Revenue Code. 2. The value of a farm purchased in Texas with community funds, comprising profits derived from the surviving wife's personal services, held, includible in the value of the deceased husband's gross estate, with the exception of the interest acquired with such profits.

1Opinion of the Court

Estate of Frank D. Neumann, Deceased, Louise J. Neumann, Independent Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent

Neumann v. Commissioner

Docket No. 11383

United States Tax Court

9 T.C. 1120; 1947 U.S. Tax Ct. LEXIS 12;

December 16, 1947, Promulgated

Decision will be entered under Rule 50.

1. Profits earned by a wife's operation of a boarding and rooming house in Texas, a community property state, held, derived from the wife's personal services within the meaning of section 811 (e), Internal Revenue Code.

2. The value of a farm purchased in Texas with community funds,…

2Cases cited8 opinions

  1. Arnold v. LeonardTexas Supreme Court · 1925
  2. Fernandez v. WienerSupreme Court of the United States · 1946
  3. Frame v. FrameTexas Supreme Court · 1931
  4. United States v. RompelSupreme Court of the United States · 1945
  5. Lilly v. YearyCourt of Appeals of Texas · 1912

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