COMMISSIONER OF INTERNAL REVENUE v. OLDS

No. 5853.

60 F.2d 252 (1932)

COMMISSIONER OF INTERNAL REVENUE v. OLDS.

Circuit Court of Appeals, Sixth Circuit.

June 29, 1932.


Attorney(s) appearing for the Case

Morton K. Rothschild, of Washington, D. C. (G. A. Youngquist, Asst. Atty. Gen., and Sewall Key, C. M. Charest, and Frank M. Thompson, all of Washington, D. C., on the brief), for petitioner.

Maxwell W. Benjamin and C. F. Stanton, both of Detroit, Mich. (Raymond H. Berry, of Detroit, Mich., and E. Barrett Prettyman and Fred Gibbs, both of Washington, D. C., on the brief), for respondent.

Before MOORMAN, HICKS, and SIMONS, Circuit Judges.


MOORMAN, Circuit Judge.

The question for decision in this case is whether an agreement which respondent made with his three daughters constituted a partnership within the meaning of section 218(a) of the Revenue Acts of 1918 and 1921 (40 Stat. 1070, 42 Stat. 245).

The respondent conducted a dock and timber business in Cheboygan, Mich. He had three daughters, one married and two unmarried. Desiring to train his daughters in the handling of large sums of money...

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