Wheelock v. Commissioner
United States Tax Court
Held, where capital rather than labor and services predominates in the production of income, the tax liability for such income follows ownership. Cf. Blair v. Commissioner, 300 U.S. 5; Lyman A. Stanton, 14 T. C. 217, affd.
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Held, where capital rather than labor and services predominates in the production of income, the tax liability for such income follows ownership. Cf. Blair v. Commissioner, 300 U.S. 5; Lyman A. Stanton, 14 T. C. 217, affd. (C. A. 7) 189 F. 2d 297, and held, where petitioners acquired by parol agreement a legal part ownership of certain oil and gas leases and producing wells, and all parties at interest recognized petitioners' ownership, respondent, for lack of privity, cannot question petitioners' title because of the statute of frauds. Cf. Francis M. Camp, 21 B. T. A. 962; Abraham Greenspon,…
1Opinion of the Court
J. N. Wheelock, Petitioner, v. Commissioner of Internal Revenue, Respondent. Wilm B. Wheelock, Petitioner, v. Commissioner of Internal Revenue, Respondent
Wheelock v. Commissioner
Docket Nos. 25449, 25450
United States Tax Court
16 T.C. 1435; 1951 U.S. Tax Ct. LEXIS 134;
June 29, 1951, Promulgated
Decisions will be entered under Rule 50.
Held, where capital rather than labor and services predominates in the production of income, the tax liability for such income follows ownership. Cf. Blair v. Commissioner, 300 U.S. 5; Lyman A. Stanton, 14 T. C. 217, affd. (C. A. 7) 189 F. 2d 297, and held, where…
2Cases cited6 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Schultz v. ScottCourt of Appeals of Texas · 1919
- Stanton v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- MacIas v. MacIasCourt of Appeals of Texas · 1941
1 more not listed; retrieve them via the Exa API.