Legal Opinion

Seidel v. Commissioner

United States Tax Court

Decided June 21, 1948No. Docket No. 13282Published

Family Partnership. -- A wife is not recognized as a partner for tax purposes where a husband conveyed one-half of his established business to her and neither rendered services to the business during the taxable years.

1Opinion of the Court

Walter F. Seidel, Petitioner, v. Commissioner of Internal Revenue, Respondent

Seidel v. Commissioner

Docket No. 13282

United States Tax Court

10 T.C. 1135; 1948 U.S. Tax Ct. LEXIS 155;

June 21, 1948, Promulgated

Decision will be entered for the respondent.

Family Partnership. -- A wife is not recognized as a partner for tax purposes where a husband conveyed one-half of his established business to her and neither rendered services to the business during the taxable years.

Allin H. Pierce, Esq., for the petitioner.

Charles D. Leist, Esq., for the respondent.

Murdock, Judge.

MURDOCK

The Commissioner…

2Cases cited5 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  3. Werner v. CommissionerUnited States Tax Court · 1946
  4. Thorrez v. CommissionerUnited States Tax Court · 1945
  5. Seidel v. CommissionerUnited States Tax Court · 1948

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