Legal Opinion

Cobb v. Commissioner

United States Tax Court

Decided September 30, 1949No. Docket No. 19711Published

1. For several years prior to December 1, 1945, petitioner was a member of a partnership engaged in the canvas business. Both prior and subsequent to his marriage in March 1945, his wife was employed in the office of the partnership as a secretary-bookkeeper. On November 30, 1945, when the partnership's sales had doubled those of the preceding year, petitioner purchased the interest of his partner and entered into an oral agreement of partnership with his wife.

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1. For several years prior to December 1, 1945, petitioner was a member of a partnership engaged in the canvas business. Both prior and subsequent to his marriage in March 1945, his wife was employed in the office of the partnership as a secretary-bookkeeper. On November 30, 1945, when the partnership's sales had doubled those of the preceding year, petitioner purchased the interest of his partner and entered into an oral agreement of partnership with his wife. Held, under the facts, the petitioner and his wife did not in good faith and acting with a business purpose intend to join together…

1Opinion of the Court

Dewey F. Cobb, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cobb v. Commissioner

Docket No. 19711

United States Tax Court

13 T.C. 495; 1949 U.S. Tax Ct. LEXIS 74;

September 30, 1949, Promulgated

Decision will be entered for the respondent.

1. For several years prior to December 1, 1945, petitioner was a member of a partnership engaged in the canvas business. Both prior and subsequent to his marriage in March 1945, his wife was employed in the office of the partnership as a secretary-bookkeeper. On November 30, 1945, when the partnership's sales had doubled those of the preceding year,…

Also in this document: Dissent.

2Cases cited2 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Cobb v. CommissionerUnited States Tax Court · 1949

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