Carroll v. Commissioner of Internal Revenue

WALKER, Circuit Judge.

Prior to September 15, 1919, a partnership, under the name W. T. Carter & Bro., existed, the members of it being W. T. Car*807ter, E. A. Carter, and Jack Thomas, who were residents of Texas. That partnership had been in existence since prior to the year 1913] and was, and always had been, engaged in the manufacture and sale of lumber at wholesale. It owned, in addition to other property and assets, growing timber; its timber assets having been acquired prior to March 1, 1913. By deed of gift made on September 15, 1919; by W. T. Carter and his wife, who owned in community…