Singletary v. Commissioner
United States Tax Court
Petitioner, from 1936 to 1939, operated a chain of filling stations under a trade name. In 1939 he executed an instrument purporting to transfer to his wife, in consideration of love and affection, an undivided one-half interest in the personal property, personal assets, and good will of the business and agreeing that thenceforth they should engage in the business as partners.
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Petitioner, from 1936 to 1939, operated a chain of filling stations under a trade name. In 1939 he executed an instrument purporting to transfer to his wife, in consideration of love and affection, an undivided one-half interest in the personal property, personal assets, and good will of the business and agreeing that thenceforth they should engage in the business as partners. The wife brought in no new capital and contributed no services, and the business was thereafter carried on as it had been carried on previously. Bookkeeping entries were made crediting one-half of the profits to…
1Opinion of the Court
Lewis Hall Singletary, Petitioner, v. Commissioner of Internal Revenue, Respondent
Singletary v. Commissioner
Docket No. 5090
United States Tax Court
5 T.C. 365; 1945 U.S. Tax Ct. LEXIS 130;
June 30, 1945, Promulgated
Decision will be entered for the respondent.
Petitioner, from 1936 to 1939, operated a chain of filling stations under a trade name. In 1939 he executed an instrument purporting to transfer to his wife, in consideration of love and affection, an undivided one-half interest in the personal property, personal assets, and good will of the business and agreeing that thenceforth they should…
Also in this document: Dissent.
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
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