West v. Commissioner
United States Tax Court
The petitioners executed formal instruments of assignment to trust of portions of their capital interests in a partnership which was engaged in the mercantile business. They named their children as beneficiaries. The then members of the partnership executed formal consents. The petitioners, as majority partners, retained all rights of management and control over the partnership and its business.
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The petitioners executed formal instruments of assignment to trust of portions of their capital interests in a partnership which was engaged in the mercantile business. They named their children as beneficiaries. The then members of the partnership executed formal consents. The petitioners, as majority partners, retained all rights of management and control over the partnership and its business. Partnership profits were to be credited on the books according to the capital interests, as shown by the books. The majority partners had the right to fix salaries of the partners and to determine…
1Opinion of the Court
William D. West, Petitioner, et al. 1 v. Commissioner of Internal Revenue, Respondent
West v. Commissioner
Docket Nos. 22734, 22735, 26417, 26418, 27799, 27800, 27801, 27803, 27804, 27805
United States Tax Court
19 T.C. 808; 1953 U.S. Tax Ct. LEXIS 242;
January 29, 1953, Promulgated
Decisions will be entered under Rule 50.
The petitioners executed formal instruments of assignment to trust of portions of their capital interests in a partnership which was engaged in the mercantile business. They named their children as beneficiaries. The then members of the partnership executed formal consents. The…
Also in this document: Dissent.
2Cases cited3 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Crowe v. United StatesCourt of Appeals for the Sixth Circuit · 1952
- West v. CommissionerUnited States Tax Court · 1953