Nelson v. Commissioner
United States Tax Court
1. In September 1934 petitioner started a wholesale linen business with approximately $ 2,500, about $ 1,000 of which was contributed by his wife. She worked constantly with him in such business until the early part of 1938. From June 1936 through 1941 petitioner also operated a hotel on leased property, with occasional assistance from his wife. Funds from all business activities of petitioner were deposited in a bank account over which he alone had control.
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1. In September 1934 petitioner started a wholesale linen business with approximately $ 2,500, about $ 1,000 of which was contributed by his wife. She worked constantly with him in such business until the early part of 1938. From June 1936 through 1941 petitioner also operated a hotel on leased property, with occasional assistance from his wife. Funds from all business activities of petitioner were deposited in a bank account over which he alone had control. The property in which the hotel business was operated was purchased on land contract in the latter part of 1939. The initial and…
1Opinion of the Court
OPINION.
Hill, Judge:
The Commissioner determined that the entire 1941 net income of $9,403.91 from the operation of the Aberdeen Hotel was taxable to petitioner under the provisions of section 22 (a) of the Internal Revenue Code. He contends that petitioner, for tax purposes, was the owner of the property, that the operation of the hotel in 1941 was the business of petitioner and hence any income derived therefrom was taxable to him.
The petitioner states that the pertinent question to be determined is “Who is the owner of the property, Albert Nelson or his wife, Goldye Jean Nelson?” and he…
2Cases cited1 opinion
- Commissioner v. TowerSupreme Court of the United States · 1946
3Cited by33 opinions
- O'Meara v. CommissionerUnited States Tax Court · 1947
- Werner v. CommissionerUnited States Tax Court · 1946
- Jacobson v. CommissionerUnited States Tax Court · 1946
- Vance v. CommissionerUnited States Tax Court · 1950
- Bartell Hotel Co. v. CommissionerUnited States Tax Court · 1959
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