Legal Opinion

Keenan v. Comm'r

United States Tax Court

Decided December 29, 1945No. Docket Nos. 3425, 3426Published

Prior to January 1941 petitioners, husband and wife, operated an auto parts concern as equal partners. The success of the business was due primarily to the activities of the husband, who was in complete control of the conduct of the business. On January 1, 1941, each of the petitioners gave one-half of his interest in the business to one of their two minor sons. The firm's books were set up to show an equal capital account for all parties.

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Prior to January 1941 petitioners, husband and wife, operated an auto parts concern as equal partners. The success of the business was due primarily to the activities of the husband, who was in complete control of the conduct of the business. On January 1, 1941, each of the petitioners gave one-half of his interest in the business to one of their two minor sons. The firm's books were set up to show an equal capital account for all parties. There was no formal partnership agreement executed at the time. The sons performed little service for the business and their withdrawals from their…

1Opinion of the Court

P. A. Keenan, Sr., Petitioner, v. Commissioner of Internal Revenue, Respondent. Mattie W. Keenan, Petitioner, v. Commissioner of Internal Revenue, Respondent

Keenan v. Comm'r

Docket Nos. 3425, 3426

United States Tax Court

5 T.C. 1371; 1945 U.S. Tax Ct. LEXIS 5;

December 29, 1945, Promulgated

Decisions will be entered for the respondent.

Prior to January 1941 petitioners, husband and wife, operated an auto parts concern as equal partners. The success of the business was due primarily to the activities of the husband, who was in complete control of the conduct of the business. On January 1, 1941, each…

2Cases cited1 opinion

  1. Keenan v. Comm'rUnited States Tax Court · 1945

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