Wilson v. Commissioner

The only question before us on this appeal is the taxability for the years 1940-41 to the petitioner, W. H. Wilson, of the income from a share of the partnership which the petitioner gave to his daughter. At the time of the gift, the daughter was 17 years old. It was not contemplated that the daughter would make any contribution either in money or services to the partnership, which was engaged in the business of buying, selling and other services in connection with cotton. And the record discloses that the daughter never made any such contributions. The Tax Court of the United States decided…