Legal Opinion

Wing v. Commissioner

United States Board of Tax Appeals

Decided October 22, 1929No. Docket No. 24499Published

INCOME - PARTNERSHIP - DISTRIBUTIVE EARNINGS. - Petitioner and his wife contributed assets jointly owned to a partnership under contract witnessing that they each held a one-sixth partnership interest.

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INCOME - PARTNERSHIP - DISTRIBUTIVE EARNINGS. - Petitioner and his wife contributed assets jointly owned to a partnership under contract witnessing that they each held a one-sixth partnership interest. Respondent included in petitioner's income the distributive earnings of the partnership paid to both petitioner and wife on their individual interests, upon the theory that the contract of partnership was invalid under state law which prohibited a partnership relation between husband and wife. Held that the beneficial ownership of a one-sixth interest in the partnership property being in…

1Opinion of the Court

R. E. WING, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Wing v. Commissioner

Docket No. 24499.

United States Board of Tax Appeals

17 B.T.A. 1028; 1929 BTA LEXIS 2198;

October 22, 1929, Promulgated

INCOME - PARTNERSHIP - DISTRIBUTIVE EARNINGS. - Petitioner and his wife contributed assets jointly owned to a partnership under contract witnessing that they each held a one-sixth partnership interest. Respondent included in petitioner's income the distributive earnings of the partnership paid to both petitioner and wife on their individual interests, upon the theory that the contract of…

2Cases cited1 opinion

  1. Wing v. CommissionerUnited States Board of Tax Appeals · 1929

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