Seidel v. Commissioner
United States Tax Court
Family Partnership. -- A wife is not recognized as a partner for tax purposes where a husband conveyed one-half of his established business to her and neither rendered services to the business during the taxable years.
1Opinion of the Court
OPINION.
Murdock, Judge:
The husband has been held taxable on all of the income in a number of cases in which it appeared that, after he had conveyed a part of his interest in the business to his wife, he continued to operate the business himself, while the wife contributed no important services. The leading cases are Commissioner v. Tower, 327 U. S. 280, and Lusthaus v. Commissioner, 327 U. S. 293. Here, as in those cases, the partnership began by the husband transferring a part of his interest in the business to his wife, following which she contributed no important services to the business.…
2Cases cited4 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Werner v. CommissionerUnited States Tax Court · 1946
- Thorrez v. CommissionerUnited States Tax Court · 1945
3Cited by1 opinion
- Seidel v. CommissionerUnited States Tax Court · 1948