Munter v. Commissioner
United States Tax Court
Where there was, in fact, no contribution of capital or services to a partnership by the wives of two partners, the partnership will not be recognized for income tax purposes as including the wives and the income from such partnership is taxable to the husbands.
1Opinion of the Court
OPINION.
Leech, Judge'.
It is petitioners’ sole contention that by the agreement entered into on May 1,1940, each made a complete gift of a one-fourth interest in the assets and business of the partnership business to his wife and by the same instrument their wives entered into partnership with them, contributing thereto, in each case, the one-fourth interest which had been coincidentally so received by them under the contract.
Respondent, on the other hand, argues that by the transaction no completed gift of any interest in the assets of the partnership was effected, that the Avives therefore…
2Cases cited2 opinions
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Tower v. CommissionerUnited States Tax Court · 1944
3Cited by10 opinions
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Akers v. CommissionerUnited States Tax Court · 1946
- State v. HitchcockSupreme Court of Minnesota · 1949
- Akers v. CommissionerUnited States Tax Court · 1946
- Decker v. CommissionerUnited States Tax Court · 1946
5 more not listed; retrieve them via the Exa API.