Greenberg v. Commissioner
United States Tax Court
Where petitioners' wives contributed neither capital nor services to two partnerships and the petitioners retained economic ownership and control of the partnership properties and income, it is held that the wives were not members of the partnership during 1941, for Federal income tax purposes; and the income thereof is properly taxable one-half to each of the petitioners.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The only question for our determination is whether partnerships, effective for income tax purposes, were in existence during 1941 among the petitioners and their respective wives with respect to Toledo Machinery Exchange Co. and L. W. Chuck Co.
The respondent has determined, and here contends, that the peti-tioneis are taxable one-half each on the income of the two companies. He asserts that no bona fide partnerships existed among the petitioners and their wives, but that there was merely an attempt to redistribute the tax burden of the petitioners without any…
2Cases cited2 opinions
- Burnet v. LeiningerSupreme Court of the United States · 1932
- Lusthaus v. CommissionerUnited States Tax Court · 1944
3Cited by14 opinions
- Schnitzer v. CommissionerUnited States Tax Court · 1949
- Keenan v. Comm'rUnited States Tax Court · 1945
- Rosenberg v. CommissionerUnited States Tax Court · 1946
- Denison v. CommissionerUnited States Tax Court · 1948
- Ewing v. CommissionerUnited States Tax Court · 1945
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