Thorrez v. Commissioner
United States Tax Court
For several years prior to 1941 the petitioners operated a metal plating business in Jackson, Michigan, as equal partners. Early in 1941 they decided to bring their wives and six of their children, three of whom were minors, into the partnership with them.
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For several years prior to 1941 the petitioners operated a metal plating business in Jackson, Michigan, as equal partners. Early in 1941 they decided to bring their wives and six of their children, three of whom were minors, into the partnership with them. They agreed among themselves that each should split up his one-fourth interest in the business among the members of his family; that the existing partnership should be dissolved; and that a new partnership should be formed by all parties contributing their interests in the business to the new partnership. In accordance with such agreement…
1Opinion of the Court
OPINION.
Smith, Judge:
Petitioners’ contentions are that after the effective date of the execution of the partnership agreement of January 3, 1941, the business of Michner Plating Co. was conducted as a partnership consisting of the 14 members, including themselves, their wives, and minor children. They contend that their wives and children are entitled to full membership in the partnership because of their contributions of undivided interests in the assets of the business which petitioners allegedly transferred to them as bona fide gifts in anticipation of the organization of the partnership.…
2Cases cited4 opinions
- Karrick v. HannamanSupreme Court of the United States · 1897
- Bowers v. Lawyers Mortgage Co.Supreme Court of the United States · 1932
- Zukaitis v. CommissionerUnited States Tax Court · 1944
- Lorenz v. CommissionerUnited States Tax Court · 1944
3Cited by15 opinions
- Apt v. BirminghamDistrict Court, N.D. Iowa · 1950
- Thorrez v. CommissionerUnited States Tax Court · 1958
- Singletary v. CommissionerUnited States Tax Court · 1945
- Appel v. SmithDistrict Court, N.D. Indiana · 1945
- Seidel v. CommissionerUnited States Tax Court · 1948
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