Legal Opinion

Easley v. Commissioner

United States Tax Court

Decided January 27, 1947No. Docket Nos. 6287, 6288Published

Petitioner W. H. Easley conducted a bottling and sales business under a contract with Seven-Up Co. of St. Louis, as a sole proprietorship. He and his wife purportedly transferred undivided interests in the business to W. H. Easley, as trustee for two minor children.

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Petitioner W. H. Easley conducted a bottling and sales business under a contract with Seven-Up Co. of St. Louis, as a sole proprietorship. He and his wife purportedly transferred undivided interests in the business to W. H. Easley, as trustee for two minor children. Upon the facts, held, that petitioners failed to make bona fide transfers of part of the business to the two trusts and, consequently, all of the income of the business is taxable to petitioners as community income.

1Opinion of the Court

W. H. Easley, Petitioner, v. Commissioner of Internal Revenue, Respondent. Margaret A. Easley, Petitioner, v. Commissioner of Internal Revenue, Respondent

Easley v. Commissioner

Docket Nos. 6287, 6288

United States Tax Court

8 T.C. 153; 1947 U.S. Tax Ct. LEXIS 305;

January 27, 1947, Promulgated

Decision will be entered for the respondent.

Petitioner W. H. Easley conducted a bottling and sales business under a contract with Seven-Up Co. of St. Louis, as a sole proprietorship. He and his wife purportedly transferred undivided interests in the business to W. H. Easley, as trustee for two minor…

2Cases cited3 opinions

  1. Lucas v. EarlSupreme Court of the United States · 1930
  2. Burnet v. LeiningerSupreme Court of the United States · 1932
  3. Easley v. CommissionerUnited States Tax Court · 1947

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