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34 T.C. 333

Crowley v. Commissioner

United States Tax Court

Decided May 31, 1960

United States Tax Court · decided 1960-05-31

1. Individual petitioners, one of whom was chief executive officer of corporate petitioner, held, not taxable on income in the form of appraisal fees, insurance commissions, and abstract and title… Held: not taxable on income in the form of appraisal fees, insurance commissions, and abstract and title policy commissions received by a partnership in which each of petitioners' four minor children had a one-fourth beneficial interest.

Good law ✅— No negative treatment on recordhow we know

Decisions will be entered under Rule 50 · Decided 1960-05-31

How this case has been cited

Cited by 7 later decisions — most recently November 2003

2019601970198019902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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Murdock, J..

¶1dissenting: All of the income here in question had to be earned by somebody performing the necessary work to bring it in. Eobert, Jr., did the work. His father and mother did not. Therefore, I do not think the income is taxable to the parents. If the loans from the parents were made at less than a proper rate of interest, a proper rate of interest could be determined and the difference taxed to the parents. But the parents did not make the loans that brought in the 6 per cent interest and they should not be taxed on that amount or upon any of the other items which the Commissioner has taxed to them.

Turner, Opper, Baum, and Pierce, //., would tax the income from the commissions and rebates to petitioners who directly or through their subservient agencies not only really earned the income but controlled and could at any time change its destination.
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