Primm v. Commissioner
United States Board of Tax Appeals
In December 1922, petitioner T. J. Primm made an oral declaration that he would operate a certain cotton-trading account for the benefit of his wife and children. In November 1923, this declaration was set forth in a written instrument in which the wife and children were designated as equal beneficiaries of "all the income of this fund." Held, the income from the trading account was first income to Primm and taxable to the marital community in 1923.
1Opinion of the Court
T. J. PRIMM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
T. J. PRIMM, TEMPORARY ADMINISTRATOR OF THE ESTATE OF MATTIE PRIMM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Primm v. Commissioner
Docket Nos. 37792, 37793.
United States Board of Tax Appeals
28 B.T.A. 13; 1933 BTA LEXIS 1198;
May 4, 1933, Promulgated
In December 1922, petitioner T. J. Primm made an oral declaration that he would operate a certain cotton-trading account for the benefit of his wife and children. In November 1923, this declaration was set forth in a written instrument in which the wife and…
2Cases cited1 opinion
- Primm v. CommissionerUnited States Board of Tax Appeals · 1933