Fischer v. Commissioner
United States Tax Court
Petitioner and two sons formed a partnership, to which all contributed capital and services. The partnership was held to be bona fide and valid for income tax purposes in William F. Fischer, 5 T. C. 507. Held, that the transaction did not result in taxable gift from petitioner under sections 501 and 503 of Revenue Act of 1932.
1Opinion of the Court
OPINION.
Harron, Judge:
The question relates to a business which had been in existence many years prior to January 1, 1939. Petitioner took his sons into partnership. In the formation of the partnership the capital contributions were equal as to the two sons, who contributed in cash $64,000, ($32,000 each). Petitioner contributed assets, including cash, amoúnting to $260,091. The partnership created under the agreement of January 1, 1939, was a bona fide partnership, valid for purposes of taxation. William F. Fischer, 5 T. C. 507. The parties to the agreement agreed that the partnership was to…
2Cases cited4 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Jones v. CommissionerUnited States Tax Court · 1943
- Hogle v. CommissionerUnited States Tax Court · 1946
- Hyman v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- Fischer v. CommissionerUnited States Tax Court · 1947