Champlin v. Commissioner
United States Board of Tax Appeals
1. A business conducted by a husband alone, to which his wife contributed funds which she was willing to loss if the business were not successful, held, upon the evidence, not to be the business of a partnership with distributable income, but the business of the husband alone, the income being entirely taxable to him. 2. The transfer in 1920 by a taxpayer of the assets of his business, including an oil lease which was the subject of an action by the taxpayer to quiet his…
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1. A business conducted by a husband alone, to which his wife contributed funds which she was willing to loss if the business were not successful, held, upon the evidence, not to be the business of a partnership with distributable income, but the business of the husband alone, the income being entirely taxable to him. 2. The transfer in 1920 by a taxpayer of the assets of his business, including an oil lease which was the subject of an action by the taxpayer to quiet his title, in exchange for shares of a newly organized corporation, held, upon the evidence, to result in taxable gain, and the…
1Opinion of the Court
H. H. CHAMPLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Champlin v. Commissioner
Docket No. 22486.
United States Board of Tax Appeals
28 B.T.A. 264; 1933 BTA LEXIS 1144;
June 6, 1933, Promulgated
1. A business conducted by a husband alone, to which his wife contributed funds which she was willing to loss if the business were not successful, held, upon the evidence, not to be the business of a partnership with distributable income, but the business of the husband alone, the income being entirely taxable to him.
2. The transfer in 1920 by a taxpayer of the assets of his business,…
2Cases cited1 opinion
- Champlin v. CommissionerUnited States Board of Tax Appeals · 1933