Legal Opinion
Wellington v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided May 13, 1952No. 10519PublishedCited by 3 opinions
1Opinion of the Court
KERNER, Circuit Judge.
This is a petition to review a decision of the Tax Court which determined that no partnership existed between petitioner and his wife for income tax purposes during the year 1943.
On July 1, 1943, petitioner and his wife executed a partnership agreement which recited that they were the equal owners of the tangible assets of a trunk company, and that they agreed to engage in the trunk and case business under the name of Wellington Trunk and Case Company. The agreement provided that petitioner was to receive 60% of the profits, and his wife, 40%.
Petitioner and his wife…
2Cases cited10 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Rupple v. KuhlCourt of Appeals for the Seventh Circuit · 1949
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3Cited by3 opinions
- Abraham Teitelbaum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
- Forman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1952
- Stoffield v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953