Legal Opinion

Simmons v. Commissioner

United States Board of Tax Appeals

Decided April 8, 1931No. Docket Nos. 31530, 44254, 48654PublishedCited by 2 opinions

1. Held that the petitioner's two daughters were members of the partnership of W. H. Simmons & Company. 2. Respondent's determination that the rentals on certain buildings were income to the petitioner disapproved.

1Opinion of the Court

*1113OPINION.

Trammell :

The petitioner contends that for the years 1924, 1925, 1926, and 1927 his two daughters were members of the partnership of W. H. Simmons & Company; that the respondent erred in determining that they were not, and that the amounts credited to them on the partnership books as profits and interest were taxable to him. The respondent contends that the daughters were not members of the partnership and that he did not commit any error in determining that the amounts credited to the daughters on the partnership books were taxable to the petitioner.

As we view all the evidence in…

2Cases cited9 opinions

  1. Steel v. Smelting Co.Supreme Court of the United States · 1882
  2. Brant v. Virginia Coal & Iron Co.Supreme Court of the United States · 1876
  3. Meehan v. ValentineSupreme Court of the United States · 1892
  4. Henshaw v. BissellSupreme Court of the United States · 1874
  5. Orvis v. . CurtissNew York Court of Appeals · 1899

4 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Marc White & Kelly White v. CommissionerUnited States Tax Court · 2018
  2. Simmons v. CommissionerUnited States Board of Tax Appeals · 1931

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