Alexander v. Commissioner
United States Tax Court
1. The petitioner, the owner of a three-fourths interest in a partnership engaged in the baking business, declared himself trustee for his wife for a one-fourth interest. The wife could not assign, pledge, or anticipate either income or corpus of the trust. Petitioner retained management of the trust and the business, as with property absolutely owned by him, and the trust income was payable to the wife only as petitioner might deem for her best interest.
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1. The petitioner, the owner of a three-fourths interest in a partnership engaged in the baking business, declared himself trustee for his wife for a one-fourth interest. The wife could not assign, pledge, or anticipate either income or corpus of the trust. Petitioner retained management of the trust and the business, as with property absolutely owned by him, and the trust income was payable to the wife only as petitioner might deem for her best interest. In case of her death, the trust estate was to revert to the petitioner. She contributed no services to the partnership. Held, that the…
1Opinion of the Court
S. Kenneth Alexander, Petitioner, v. Commissioner of Internal Revenue, Respondent
Alexander v. Commissioner
Docket No. 2359
United States Tax Court
6 T.C. 804; 1946 U.S. Tax Ct. LEXIS 222;
April 23, 1946, Promulgated
Decisions will be entered under Rule 50.
1. The petitioner, the owner of a three-fourths interest in a partnership engaged in the baking business, declared himself trustee for his wife for a one-fourth interest. The wife could not assign, pledge, or anticipate either income or corpus of the trust. Petitioner retained management of the trust and the business, as with property absolutely…
2Cases cited7 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Overton v. CommissionerUnited States Tax Court · 1946
- Mather v. CommissionerUnited States Tax Court · 1945
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