Crabb v. Commissioner
United States Board of Tax Appeals
1. In 1932 each petitioner owned an undivided one-fourth interest in a Texas ranch as his or her separate property. They conveyed the ranch to trustees for a period of ten years. The trust was named "jas. F. Welder Heirs."
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1. In 1932 each petitioner owned an undivided one-fourth interest in a Texas ranch as his or her separate property. They conveyed the ranch to trustees for a period of ten years. The trust was named "jas. F. Welder Heirs." The trustees were to hold the lands together in their entirety; they were to conduct a ranch and farm business thereon with full powers to collect all moneys, pay all bills, and remit to each petitioner annually one-fourth of such profits as in the discretion of the trustees were not needed in the business; they were given authority to lease the lands for oil and gas…
1Opinion of the Court
*695OPINION.
Black:
We shall first consider assignment of error (b). In approaching this issue a brief review of what the parties have done and are now contending may be helpful. A partnership return for Jas. F. Welder Heirs was filed for 1936 showing a net income of $399,-183.50, on which return each petitioner was listed as being entitled to a one-fourth distributive share in its net income. Petitioners in their individual returns reported their so-called distributive share as if the net income of $399,183.50 was composed of the difference between separate net income of $409,089 and a convrmmity…
2Cases cited6 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Hopkins v. BaconSupreme Court of the United States · 1930
- Stephens v. StephensCourt of Appeals of Texas · 1927
- Stanolind Oil & Gas Co. v. Simpson-Fell Oil Co.Court of Appeals of Texas · 1935
1 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Sneed v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1941
- Bosworth v. CommissionerUnited States Tax Court · 1943
- Crabb v. CommissionerUnited States Board of Tax Appeals · 1940
- Crabb v. CommissionerUnited States Board of Tax Appeals · 1942