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eBook details

• Title: Cobb v. Commissioner of Internal Revenue
• Author : United States Court Of Appeals Sixth Circuit
• Release Date : January 04, 1950
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 63 KB

Description

Once again we are confronted with the problem of the result, taxwise, in the creation of a family partnership. The diverse interpretations that have been given by courts to the rationale of Commissioner of Internal Revenue v. Tower, 327 U.S. 280, 66 S. Ct. 532, 90 L. Ed. 670, need no longer trouble us in view of the illumination shed upon that case by the careful reasoning of the court in the later case of Commissioner of Internal Revenue v. Culbertson, 337 U.S. 733, 69 S. Ct. 1210, 93 L. Ed. 1659. Moreover, there is now a broader review of the fact findings of the Tax Court by the test applied to such findings in the 1948 Judicial Code. § 36, Act of June 25, 1948, 26 U.S.C.A. § 1141(a). This test imposes upon us the duty of careful scrutiny of the record to determine whether or not such findings are clearly erroneous. This being so, consideration of cases decided before the effective date of the 1948 codification become of doubtful 51lu5 9 n the consideration of the present problem, though we are, of course, bound by such findings, if they are supported by substantial evidence and there is reasonable basis in the record for them.

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