Legal Opinion
Goold v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 4, 1950No. 12296PublishedCited by 5 opinions
1Opinion of the Court
GOODMAN, District Judge.
The propriety of respondent Commissioner’s determination that the petitioner received a partnership interest from his father by gift rather than by sale, is the issue tendered by this appeal from the Tax Court’s decision, affirming respondent’s determination.
Respondent assessed income tax deficiencies for the year 1943 against petitioner upon the theory that a partnership interest transferred by his father to petitioner was a gift and hence his separate property, making the income therefrom separate property. 1 The petitioner treated his income from the partnership as…
2Cases cited14 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Superior Oil Co. v. Mississippi Ex Rel. KnoxSupreme Court of the United States · 1930
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
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3Cited by5 opinions
- Commissioner of Internal Revenue v. Mildred Irene SiegelCourt of Appeals for the Ninth Circuit · 1957
- 58th St. Plaza Theatre, Inc. v. Commissioner of Internal Revenue. Brecher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- 58th St. Plaza Theatre, Inc. v. Commissioner of Internal Revenue. Brecher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- 58th St. Plaza Theatre, Inc. v. Commissioner of Internal Revenue. Brecher v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Fleishman v. United StatesDistrict Court, D. Oregon · 1953