Epps v. Commissioner

Sixth Circuit

Epps v. Commissioner

164 F.2d 482

CourtCourt of Appeals for the Sixth Circuit

DecidedNovember 3, 1947

DocketNo. 10407

StatusPublished

This text of 164 F.2d 482 (Epps v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Epps v. Commissioner, 164 F.2d 482 (6th Cir. 1947).

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Opinion

PER CURIAM.

It appearing that the taxpayer was adjudicated liable for 60% of the income earned by a family partnership, to the capital of which he had contributed by a loan to his wife and a gift to the trustee of his minor daughter, that the partnership was in a real sense a continuation of a corporate business in which the taxpayer had the controlling interest, and that the successful operation of the partnership business was due in large measure to the goodwill and contracts of the taxpayer and his son,

It is our view that the Tax Court’s findings are supported by substantial evidence, support the inferences drawn from such findings, and that the conclusions of the Tax Court apply to the facts the applicable law, wherefore,

The decision of the Tax Court is affirmed upon the findings made and the reasons given in its memorandum opinion.

It is so ordered.

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PER CURIAM.

It appearing that the taxpayer was adjudicated liable for 60% of the income earned by a family partnership, to the capital of which he had contributed by a loan to his wife and a gift to the trustee of his minor daughter, that the partnership was in a real sense a continuation of a corporate business in which the taxpayer had the controlling interest, and that the successful operation of the partnership business was due in large measure to the goodwill and contracts of the taxpayer and his son,

It is our view that the Tax Court’s findings are supported by substantial evidence, support the inferences drawn from such findings, and that the conclusions of the Tax Court apply to the facts the applicable law, wherefore,

The decision of the Tax Court is affirmed upon the findings made and the reasons given in its memorandum opinion.

It is so ordered.

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Bluebook (online)

164 F.2d 482, Counsel Stack Legal Research, https://law.counselstack.com/opinion/epps-v-commissioner-ca6-1947.