Crowley v. Commissioner
United States Tax Court
1. Individual petitioners, one of whom was chief executive officer of corporate petitioner, held, not taxable on income in the form of appraisal fees, insurance commissions, and abstract and title policy commissions received by a partnership in which each of petitioners' four minor children had a one-fourth beneficial interest.
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1. Individual petitioners, one of whom was chief executive officer of corporate petitioner, held, not taxable on income in the form of appraisal fees, insurance commissions, and abstract and title policy commissions received by a partnership in which each of petitioners' four minor children had a one-fourth beneficial interest. Petitioners' control of who should perform this subsidiary business generated by corporate petitioner's lending activities does not make petitioners taxable on the income derived therefrom by the partnership which performed the services and in which petitioners were…
1Opinion of the Court
DeenNen, Judge:
This consolidated proceeding involves deficiencies in income tax and additions to tax determined against petitioners as follows:
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Tbs issues for decision are: (1) Whether the income reported by the Crowley Company in 1952 and 1953, a purported partnership of the individual petitioners’ children, is attributable to and in-cludible in the income of individual petitioners Robert P. and Mary D. Crowley; (2) whether income from abstract and title policy commissions reported by the Crowley Company and Crowley Corporation in 1953 and 1954, respectively, is attributable to…
2Cases cited16 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
11 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Durkin v. CommissionerUnited States Tax Court · 1986
- Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983
- Local Finance Corp. v. CommissionerUnited States Tax Court · 1967
- Alabama-Georgia Syrup Co. v. CommissionerUnited States Tax Court · 1961
10 more not listed; retrieve them via the Exa API.