Mendelsohn v. Commissioner

Third Circuit

Mendelsohn v. Commissioner

186 F.2d 306

CourtCourt of Appeals for the Third Circuit

DecidedJanuary 25, 1951

DocketNos. 10285, 10286

StatusPublished

This text of 186 F.2d 306 (Mendelsohn v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Mendelsohn v. Commissioner, 186 F.2d 306 (3d Cir. 1951).

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Opinion

PER CURIAM.

The petitioners, the Mendelsohns, seek review of the decisions of the Tax Court holding that the petitioners’ attempt to show that it was their true intention to enter into a partnership with their 12% year old daughter was unsuccessful. See Commissioner v. Culbertson, 337 U.S. 733, 69 S.Ct. 1210, 93 L.Ed. 1659. cf. Lamb v. Smith, 3 Cir., 183 F.2d 938 and Davis v. Commissioner of Internal Revenue, 3 Cir., 161 F.2d 361. The question presented is simply one of fact and we cannot say that the Tax Court’s holding on this point was clearly erroneous; indeed, if the question were presented to us de novo, we would arrive at the conclusion reached by the Tax Court.

The decisions of the Tax Court are correct and will be affirmed.

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PER CURIAM.

The petitioners, the Mendelsohns, seek review of the decisions of the Tax Court holding that the petitioners’ attempt to show that it was their true intention to enter into a partnership with their 12% year old daughter was unsuccessful. See Commissioner v. Culbertson, 337 U.S. 733, 69 S.Ct. 1210, 93 L.Ed. 1659. cf. Lamb v. Smith, 3 Cir., 183 F.2d 938 and Davis v. Commissioner of Internal Revenue, 3 Cir., 161 F.2d 361. The question presented is simply one of fact and we cannot say that the Tax Court’s holding on this point was clearly erroneous; indeed, if the question were presented to us de novo, we would arrive at the conclusion reached by the Tax Court.

The decisions of the Tax Court are correct and will be affirmed.

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186 F.2d 306, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mendelsohn-v-commissioner-ca3-1951.

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