Belcher v. Commissioner of Internal Revenue

WALLER, Circuit Judge.

This is the case of another family partnership composed of the husband, his wife as trustee for their four minor children, and the wife individually, wherein the Tax Court found, 1 2 with evidence .to support its findings, that the husband [Taxpayer] had set up the four trusts and had then made gifts of the five partnership interests in his saw mill business to the members of his family for Federal income tax purposes, ralher than for the prime purpose of carrying on the business at hand, and that since neither of his partners had either contributed capital originating…