Eisenmann v. Commissioner

OPINION.

Bice, Judge:

In determining the deficiencies for the taxable years, respondent taxed all of the partnership income to the petitioner. He contends that petitioner and the trustee were not real partners in the conduct of the business during any of the taxable years. His position is that “petitioner as grantor of the trust retained directly or indirectly the benefits and control over the trust corpus and the income therefrom, and that the arrangement made by the petitioner, although through formal instruments, amounts to no more than a reallocation of the income from Louis-White Motors…