Semmler v. Commissioner of Internal Revenue

Sixth Circuit

Semmler v. Commissioner of Internal Revenue

173 F.2d 218

CourtCourt of Appeals for the Sixth Circuit

DecidedFebruary 14, 1949

DocketNo. 10765

StatusPublished

This text of 173 F.2d 218 (Semmler v. Commissioner of Internal Revenue) 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

Semmler v. Commissioner of Internal Revenue, 173 F.2d 218 (6th Cir. 1949).

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Opinion

PER CURIAM.

This case came on to be heard upon the record and briefs and oral argument of counsel.

And it appearing that the Tax Court of the United States, in elaborate findings of fact and conclusions of law, held that the income of the Wholesale Supply Company, a partnership belonging to the four minor sons of the petitioner, should be included in the gross income of the petitioner because such company remained under petitioner’s control after he had made a gift of the business to his minor sons, and because he received substantial economic benefits therefrom after making the gift;

And it appearing that the findings of fact of the Tax Court are amply sustained by the record, and that it correctly applied the applicable law in its legal conclusions:

It is, ordered that the decision of the Tax Court be, and it hereby is, affirmed.

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PER CURIAM.

This case came on to be heard upon the record and briefs and oral argument of counsel.

And it appearing that the Tax Court of the United States, in elaborate findings of fact and conclusions of law, held that the income of the Wholesale Supply Company, a partnership belonging to the four minor sons of the petitioner, should be included in the gross income of the petitioner because such company remained under petitioner’s control after he had made a gift of the business to his minor sons, and because he received substantial economic benefits therefrom after making the gift;

And it appearing that the findings of fact of the Tax Court are amply sustained by the record, and that it correctly applied the applicable law in its legal conclusions:

It is, ordered that the decision of the Tax Court be, and it hereby is, affirmed.

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Bluebook (online)

173 F.2d 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/semmler-v-commissioner-of-internal-revenue-ca6-1949.