Legal Opinion

Lang v. Commissioner

United States Tax Court

Decided June 4, 1946No. Docket No. 4444PublishedCited by 1 opinion

Family Partnership. -- Petitioner's wife and four minor children were not partners with him within the meaning of the Internal Revenue Code in conducting the business and earning the income of the Lang Co. during 1941.

1Opinion of the Court

OPINION.

Murdock, Judge:

This is another case in which the Commissioner has refused to recognize for income tax purposes a family arrangement in the form of a, partnership agreement under which the wife and minor children rendered no services and brought no capital to the business owned and conducted by the husband, except as he attempted to divide among them a part of his existing interest in the business. It is now well established that all of the income of the business under such circumstances is taxable to the husband. Commissioner v. Tower, 327 U. S. 280; Lusthaus v. Commissioner, 327 U.…

2Cases cited4 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  3. Parker v. CommissionerUnited States Tax Court · 1946
  4. Mauldin v. CommissionerUnited States Tax Court · 1945

3Cited by1 opinion

  1. Lang v. CommissionerUnited States Tax Court · 1946

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