Legal Opinion

Smith v. Commissioner

United States Tax Court

Decided May 18, 1944No. Docket No. 111723Published

In consideration of love and affection and the assumption by his wife of equal and joint liability on his obligations petitioner, by an acknowledged written instrument, transferred to his wife a one-half interest in a lumber-manufacturing business theretofore owned by petitioner in sole proprietorship and immediately thereafter they entered into a partnership agreement under which the petitioner put into the business his remaining one-half interest and his wife put into the…

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In consideration of love and affection and the assumption by his wife of equal and joint liability on his obligations petitioner, by an acknowledged written instrument, transferred to his wife a one-half interest in a lumber-manufacturing business theretofore owned by petitioner in sole proprietorship and immediately thereafter they entered into a partnership agreement under which the petitioner put into the business his remaining one-half interest and his wife put into the business the one-half interest so transferred to her, the profits and losses to be thereafter shared equally by…

1Opinion of the Court

M. W. Smith, Jr., Petitioner, v. Commissioner of Internal Revenue, Respondent

Smith v. Commissioner

Docket No. 111723

United States Tax Court

3 T.C. 894; 1944 U.S. Tax Ct. LEXIS 116;

May 18, 1944, Promulgated

Decision will be entered under Rule 50.

In consideration of love and affection and the assumption by his wife of equal and joint liability on his obligations petitioner, by an acknowledged written instrument, transferred to his wife a one-half interest in a lumber-manufacturing business theretofore owned by petitioner in sole proprietorship and immediately thereafter they entered into a…

Also in this document: Dissent.

2Cases cited4 opinions

  1. Tower v. CommissionerUnited States Tax Court · 1944
  2. Lorenz v. CommissionerUnited States Tax Court · 1944
  3. Lowry v. CommissionerUnited States Tax Court · 1944
  4. Smith v. CommissionerUnited States Tax Court · 1944

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