Legal Opinion

Schreiber v. Commissioner

United States Tax Court

Decided April 12, 1946No. Docket Nos. 3737, 3738Published

1. Petitioners in 1930 purchased as partners a going business in part with money furnished by their wives, one of whom was not repaid. In January 1937 each conveyed to his wife a one-fourth interest in the partnership, and in January 1938 they formed a partnership with the wives. The wives had no income from 1930 to 1936. The partnership activities continued to be managed by the husbands, the wives doing only minor work, generally in the evening at home.

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1. Petitioners in 1930 purchased as partners a going business in part with money furnished by their wives, one of whom was not repaid. In January 1937 each conveyed to his wife a one-fourth interest in the partnership, and in January 1938 they formed a partnership with the wives. The wives had no income from 1930 to 1936. The partnership activities continued to be managed by the husbands, the wives doing only minor work, generally in the evening at home. Only the petitioners could sign partnership checks. The husbands drew salaries. Held, that the Commissioner did not err in including all…

1Opinion of the Court

Abe Schreiber, Petitioner, v. Commissioner of Internal Revenue, Respondent. J. C. Shaprow, Petitioner, v. Commissioner of Internal Revenue, Respondent

Schreiber v. Commissioner

Docket Nos. 3737, 3738

United States Tax Court

6 T.C. 707; 1946 U.S. Tax Ct. LEXIS 233;

April 12, 1946, Promulgated

Decision will be entered under Rule 50.

1. Petitioners in 1930 purchased as partners a going business in part with money furnished by their wives, one of whom was not repaid. In January 1937 each conveyed to his wife a one-fourth interest in the partnership, and in January 1938 they formed a partnership with the…

Also in this document: Dissent.

2Cases cited1 opinion

  1. Schreiber v. CommissionerUnited States Tax Court · 1946

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