O'Donnell v. Commissioner
United States Tax Court
1. Held, that the daughters of the petitioners Jeremiah O'Donnell, Sr. and Margaret O'Donnell and the sister of Margaret O'Donnell were, together with the senior O'Donnells, bona fide members of a partnership, and that therefore the respondent erred in allocating to the senior O'Donnells the shares of partnership income reported as belonging to the two daughters and the sister. 2. Held, that the acquisition of control of a corporation, Wuskanut, by the partnership, was for…
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1. Held, that the daughters of the petitioners Jeremiah O'Donnell, Sr. and Margaret O'Donnell and the sister of Margaret O'Donnell were, together with the senior O'Donnells, bona fide members of a partnership, and that therefore the respondent erred in allocating to the senior O'Donnells the shares of partnership income reported as belonging to the two daughters and the sister. 2. Held, that the acquisition of control of a corporation, Wuskanut, by the partnership, was for the purpose of avoidance or evasion of Federal income tax by securing the benefit of the net operating loss of that…
1Opinion of the Court
Jeremiah J. O'Donnell, Jr., et al. * v. Commissioner.
O'Donnell v. Commissioner
Docket Nos. 94912-94916.
United States Tax Court
T.C. Memo 1964-38; 1964 Tax Ct. Memo LEXIS 298; 23 T.C.M. (CCH) 210; T.C.M. (RIA) 64038;
February 19, 1964
1. Held, that the daughters of the petitioners Jeremiah O'Donnell, Sr. and Margaret O'Donnell and the sister of Margaret O'Donnell were, together with the senior O'Donnells, bona fide members of a partnership, and that therefore the respondent erred in allocating to the senior O'Donnells the shares of partnership income reported as belonging to the two daughters and…
2Cases cited34 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
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3Cited by3 opinions
- Ketter v. CommissionerUnited States Tax Court · 1978
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- Vaughters v. CommissionerUnited States Tax Court · 1988