Legal Opinion

Kammerdiner v. Commissioner

United States Board of Tax Appeals

Decided February 10, 1932No. Docket Nos. 41643, 46555Published

Where husband and wife enter into an oral agreement for the conduct of a business to which each is to contribute service and the necessary capital is to be drawn from a joint bank account theretofore established and where each is to take one-half the profits or bear one-half the losses as the case may be, there is a partnership and each is taxable upon one-half the distributable income thereof.

1Opinion of the Court

J. KAMMERDINER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Kammerdiner v. Commissioner

Docket Nos. 41643, 46555.

United States Board of Tax Appeals

25 B.T.A. 495; 1932 BTA LEXIS 1513;

February 10, 1932, Promulgated

Where husband and wife enter into an oral agreement for the conduct of a business to which each is to contribute service and the necessary capital is to be drawn from a joint bank account theretofore established and where each is to take one-half the profits or bear one-half the losses as the case may be, there is a partnership and each is taxable upon one-half the…

2Cases cited1 opinion

  1. Kammerdiner v. CommissionerUnited States Board of Tax Appeals · 1932

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