Jackson v. Commissioner
United States Tax Court
Family Partnership -- Husband and Wife -- Wife not Recognized. -- The evidence does not establish that the wife of the petitioner, the petitioner, and others intended to enter into a contract of partnership in 1939, or in 1943, by which the petitioner's wife would become a partner in an established partnership of which the petitioner was a member.
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Family Partnership -- Husband and Wife -- Wife not Recognized. -- The evidence does not establish that the wife of the petitioner, the petitioner, and others intended to enter into a contract of partnership in 1939, or in 1943, by which the petitioner's wife would become a partner in an established partnership of which the petitioner was a member. Accordingly, it is held: That the wife of the petitioner was not a partner in a partnership, in which he was a member, during the taxable years 1943 and 1944, and that the petitioner is taxable on a four-ninths share of the partnership income for…
1Opinion of the Court
Hugh C. Jackson, Petitioner, v. Commissioner of Internal Revenue, Respondent
Jackson v. Commissioner
Docket No. 21207
United States Tax Court
19 T.C. 133; 1952 U.S. Tax Ct. LEXIS 56;
November 6, 1952, Promulgated
Decision will be entered for the respondent.
Family Partnership -- Husband and Wife -- Wife not Recognized. -- The evidence does not establish that the wife of the petitioner, the petitioner, and others intended to enter into a contract of partnership in 1939, or in 1943, by which the petitioner's wife would become a partner in an established partnership of which the petitioner was a…
2Cases cited22 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Quock Ting v. United StatesSupreme Court of the United States · 1891
- Meehan v. ValentineSupreme Court of the United States · 1892
- Carmack Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
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