Sunlin v. Commissioner
United States Board of Tax Appeals
The petitioner and his wife, prior to their marriage on April 9, 1919, formed a business partnership in Michigan, each contributing property and services, and in the profits of which partnership they were to share equally. The business was conducted in the same manner after marriage as before. The income arising during the period April 9, 1919, to December 31, 1923, from the business, was taxed all to the husband, the petitioner.
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The petitioner and his wife, prior to their marriage on April 9, 1919, formed a business partnership in Michigan, each contributing property and services, and in the profits of which partnership they were to share equally. The business was conducted in the same manner after marriage as before. The income arising during the period April 9, 1919, to December 31, 1923, from the business, was taxed all to the husband, the petitioner. Held, that one-half of the income was the property and income of the wife and should not have been included in petitioner's income.
1Opinion of the Court
L. F. SUNLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sunlin v. Commissioner
Docket No. 7483.
United States Board of Tax Appeals
6 B.T.A. 1232; 1927 BTA LEXIS 3303;
May 4, 1927, Promulgated
The petitioner and his wife, prior to their marriage on April 9, 1919, formed a business partnership in Michigan, each contributing property and services, and in the profits of which partnership they were to share equally. The business was conducted in the same manner after marriage as before. The income arising during the period April 9, 1919, to December 31, 1923, from the business, was…
2Cases cited3 opinions
- Gillespie v. BeecherMichigan Supreme Court · 1892
- Sunlin v. CommissionerUnited States Board of Tax Appeals · 1927
- Appeals of Estate of RandallUnited States Board of Tax Appeals · 1926