Legal Opinion
W. T. S. Montgomery v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 7, 1956No. 15600PublishedCited by 6 opinions
1Opinion of the Court
CAMERON, Circuit Judge.
The question presented by this appeal1 is whether the record warrants the Tax Court’s conclusion that taxpayer remained the substantial owner of a business managed and operated by him, despite transfer of legal title to the business assets to his wife, so that the fifty percent portion of the business income ascribed to the wife remained taxable to the taxpayer under Section 22(a) of the Internal Revenue Code of 1939, 26 U.S. C.A. The taxpayer, W. T. S. Montgomery, had, for the years 1946 and 1947, returned and paid taxes on fifty percent of the net income of the…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
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3Cited by6 opinions
- Haberman Farms, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1962
- Ach v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1966
- Eckel v. CommissionerUnited States Tax Court · 1974
- Haberman Farms, Inc. v. United States of America, George Haberman and Fannie H. Haberman v. United States of America, Rex Haberman and Phyllis Haberman v. United StatesCourt of Appeals for the Eighth Circuit · 1962
- Pauline W. Ach v. Commissioner of Internal Revenue, Estate of Ernest M. Ach, Deceased, Pauline W. Ach, Sole Legatee, and Pauline W. Ach, Surviving Wife v. Commissioner of Internal Revenue, the Ach Corporation v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. The Ach CorporationCourt of Appeals for the Sixth Circuit · 1966
1 more not listed; retrieve them via the Exa API.