Dickinson v. Commissioner
United States Board of Tax Appeals
Petitioner, his wife and daughter were residents of Michigan, and conducted a business under the name of the American Metal Weatherstrip Company. The respondent determined that all of the income from this business belonged to petitioner. Upon the record, held, that one-third of the income of such business belonged to the wife and one-third to the daughter. L. F. Sunlin, 6. B.T.A. 1232, and other cases, followed.
1Opinion of the Court
*1216OPINION.
Love:
The issue here presented is what portion of the net income of the business carried on under the name of the American Metal Weatherstrip Company for the calendar years 1923 to 1926, inclusive, was income to petitioner. The respondent has determined that the business was a sole proprietorship carried on by petitioner as an individual, and that all of the income therefrom was taxable to him. Petitioner contends that the business was that of a partner*1217ship between himself, his wife and daughter; that the profits and losses were to be shared equally among the three partners; and that,…
2Cases cited6 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Artman v. FergusonMichigan Supreme Court · 1888
- Bassett v. ShepardsonMichigan Supreme Court · 1883
- Gillespie v. BeecherMichigan Supreme Court · 1892
- Wineman v. PhillipsMichigan Supreme Court · 1892
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Dickinson v. CommissionerUnited States Board of Tax Appeals · 1931
- Frank Trust of 1927 v. CommissionerUnited States Board of Tax Appeals · 1941
- McCullough v. CommissionerUnited States Tax Court · 1944
- Nathan v. CommissionerUnited States Tax Court · 1943