Legal Opinion

Eisenmann v. Commissioner

United States Tax Court

Decided February 29, 1952No. Docket Nos. 23929, 24697Published

Louis R. Eisenmann conveyed a half interest in his business, in trust for the benefit of his minor son. The trust was irrevocable, and the trustee was vested with full and complete powers of management and control. The trustee was a business acquaintance but otherwise unrelated to the grantor. A partnership agreement between the grantor and the trustee to operate a business was a part of the trust agreement.

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Louis R. Eisenmann conveyed a half interest in his business, in trust for the benefit of his minor son. The trust was irrevocable, and the trustee was vested with full and complete powers of management and control. The trustee was a business acquaintance but otherwise unrelated to the grantor. A partnership agreement between the grantor and the trustee to operate a business was a part of the trust agreement. The trustee accepted the trust and actively participated in the management and operation of the partnership and a related partnership formed thereafter. Respondent taxed the income…

1Opinion of the Court

Louis R. Eisenmann and Marguerite W. Eisenmann, Petitioners, v. Commissioner of Internal Revenue, Respondent

Eisenmann v. Commissioner

Docket Nos. 23929, 24697

United States Tax Court

17 T.C. 1426; 1952 U.S. Tax Ct. LEXIS 262;

February 29, 1952, Promulgated

Decision will be entered under Rule 50.

Louis R. Eisenmann conveyed a half interest in his business, in trust for the benefit of his minor son. The trust was irrevocable, and the trustee was vested with full and complete powers of management and control. The trustee was a business acquaintance but otherwise unrelated to the grantor. A partnership…

2Cases cited9 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Stern v. CommissionerUnited States Tax Court · 1950
  3. Feldman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1950
  4. Feldman v. CommissionerUnited States Tax Court · 1950
  5. Greenberger v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1949

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