Legal Opinion

Boyt v. Commissioner

United States Tax Court

Decided September 19, 1952No. Docket Nos. 23940, 23941, 23942, 23943, 23944, 23945, 23946, 23947Published

1. Deduction -- Salary of Employee. -- Amount allowed by respondent sustained, upon failure to show extent or value of services rendered. 2. Partnership. -- Held, that three wives became bona fide partners in a general partnership with their respective husbands and several other persons. 3. Trusts -- Share of Partnership Net Income. -- Certain members of a general partnership made transfers in trust by gifts of percentage interests in the partnership.

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1. Deduction -- Salary of Employee. -- Amount allowed by respondent sustained, upon failure to show extent or value of services rendered. 2. Partnership. -- Held, that three wives became bona fide partners in a general partnership with their respective husbands and several other persons. 3. Trusts -- Share of Partnership Net Income. -- Certain members of a general partnership made transfers in trust by gifts of percentage interests in the partnership. The trusts were neither partners nor subpartners or joint venturers with the respective grantors. Each grantor retained dominion and control…

1Opinion of the Court

J. W. Boyt, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Boyt v. Commissioner

Docket Nos. 23940, 23941, 23942, 23943, 23944, 23945, 23946, 23947

United States Tax Court

18 T.C. 1057; 1952 U.S. Tax Ct. LEXIS 100;

September 19, 1952, Promulgated

Decisions will be entered under Rule 50.

1. Deduction -- Salary of Employee. -- Amount allowed by respondent sustained, upon failure to show extent or value of services rendered.

2. Partnership. -- Held, that three wives became bona fide partners in a general partnership with their respective husbands and several other persons.

3.…

2Cases cited1 opinion

  1. Boyt v. CommissionerUnited States Tax Court · 1952

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