Depue v. Commissioner
United States Tax Court
Under the facts, a valid partnership for purposes of taxation held to have been in existence in the taxable year between Frederick A. Depue, now deceased, and his wife.
1Opinion of the Court
OPINION.
HaRLan, Judge:
The above findings of fact would seem to dispose of the question of law without much discussion.
The Supreme Court of the United States, in Commissioner v. Tower, 327 U. S. 280, stated that important elements to be considered in determining whether a husband-wife partnership was valid for income tax purposes were the origin of the partnership capital, the contribution to the control and management of the business by the husband and wife, the performing of vital services by the partners, and a combination of all of the above factors,.together with all other surrounding…
Also in this document: Concurrence.
2Cases cited5 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Anderson v. CommissionerUnited States Tax Court · 1946
- Goodman v. CommissionerUnited States Tax Court · 1946
- Blumberg v. CommissionerUnited States Tax Court · 1948
3Cited by1 opinion
- Depue v. CommissionerUnited States Tax Court · 1949