Seidel v. Commissioner
United States Tax Court
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
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Werner v. CommissionerUnited States Tax Court · 1946
- Thorrez v. CommissionerUnited States Tax Court · 1945
- Seidel v. CommissionerUnited States Tax Court · 1948