T. M. Stanback, T. M. Stanback and Ada M. Stanback, Fred J. Stanback, Fred J. Stanback and Elizabeth C. Stanback v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
1Opinion of the Court
HAYNSWORTH, Circuit Judge.
Here we deal with the taxation of the income of a family partnership during years preceding 1951. Involved are questions of collateral estoppel to relitigate the tax recognition of the partnership agreement and of the Commissioner’s duty to tax capital earnings proportionately to the owners of the capital.
The taxpayers, two brothers, had a proprietary medicine business which they conducted as partners. In 1937 and 1938, each transferred an undivided six per cent interest in the partnership to each of three trusts he had created for the benefit of his wife and minor…
2Cases cited10 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Blair v. CommissionerSupreme Court of the United States · 1937
- German v. CommissionerUnited States Tax Court · 1943
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3Cited by17 opinions
- Woodbury v. CommissionerUnited States Tax Court · 1967
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- Max Kuney, Jr., and Constance K. Kuney, His Wife Max J. Kuney, Sr., Olive R. Kuney v. William E. Frank, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Lea, Inc. v. CommissionerUnited States Tax Court · 1978
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