COMMISSIONER v. SUNNEN

No. 227.

333 U.S. 591 (1948)

COMMISSIONER OF INTERNAL REVENUE v. SUNNEN.

Supreme Court of United States.

Decided April 5, 1948.


Attorney(s) appearing for the Case

Arnold Raum argued the cause for petitioner. With him on the brief were Solicitor General Perlman, Assistant Attorney General Caudle, Helen R. Carloss and L.W. Post.

C. Powell Fordyce argued the cause and filed a brief for respondent.


Opinion of the Court by MR. JUSTICE MURPHY, announced by MR. JUSTICE RUTLEDGE.

The problem of the federal income tax consequences of intra-family assignments of income is brought into focus again by this case.

The stipulated facts concern the taxable years 1937 to 1941, inclusive, and may be summarized as follows:

The respondent taxpayer was an inventor-patentee and the president of the Sunnen Products Company, a corporation engaged in the manufacture...

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