Toor v. Westover. Toor v. Westover

ORR, Circuit Judge.

This is a family partnership case. These cases represent a phase in the history of income tax litigation which reflects the increasing efforts on the part of taxpayers to distribute the impact of taxation among members of a close family group without substantially altering control over the income, producing property and the attempts of Congress and the Commissioner of Internal Revenue to insure that income from property will be taxable to the substantial owner of that property and income from personal services will be taxable to the person rendering those services.

The…