Guggenheimer v. Commissioner
United States Tax Court
The taxpayer and his brother and sister acquired by their mother's will securities and rented buildings which they held as partners from 1928 until 1940. The taxpayer, acting as manager, operated the properties at a constant loss, and individually advanced funds for operation and conservation, which were credited to his account and charged against the three partners.
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The taxpayer and his brother and sister acquired by their mother's will securities and rented buildings which they held as partners from 1928 until 1940. The taxpayer, acting as manager, operated the properties at a constant loss, and individually advanced funds for operation and conservation, which were credited to his account and charged against the three partners. In 1939 the brother and sister demanded an accounting, which disclosed insolvency and indicated substantial amounts due from them; the taxpayer had a credit balance. The brother and sister rejected the accounting, and in 1940 the…
1Opinion of the Court
Charles S. Guggenheimer and Minnie S. Guggenheimer, Petitioners, v. Commissioner of Internal Revenue, Respondent
Guggenheimer v. Commissioner
Docket No. 8813
United States Tax Court
8 T.C. 789; 1947 U.S. Tax Ct. LEXIS 232;
April 9, 1947, Promulgated
Decision will be entered under Rule 50.
The taxpayer and his brother and sister acquired by their mother's will securities and rented buildings which they held as partners from 1928 until 1940. The taxpayer, acting as manager, operated the properties at a constant loss, and individually advanced funds for operation and conservation, which were credited…
2Cases cited3 opinions
- Herrick v. GuildAppellate Division of the Supreme Court of the State of New York · 1939
- Guggenheimer v. CommissionerUnited States Tax Court · 1947
- Lasky v. CoverdaleAppellate Terms of the Supreme Court of New York · 1914