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Commissioner Vs. Culbertson
Cites for this judgment
- US Supreme Court
- Jun 27, 1949
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U.S. 733 (1949) U.S. Supreme Court Commissioner v. CulbertsonSearch
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U.S. 733 (1949) Commissioner v. CulbertsonSearch
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We granted certiorari, 335 U.S. 883, to consider the Commissioner's claim that the principles of Commissioner v. TowerSearch
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U. S. 280 , and Lusthaus v. CommissionerSearch
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from the ranch that brings this case into the courts. First. The Tax Court read our decisions in Commissioner v. TowerSearch
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supra, and Lusthaus v. CommissionerSearch
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that income must Page 337 U. S. 740 be taxed to him who earns it. Lucas v. EarlSearch
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U. S. 422 . Furthermore, our decision in Commissioner v. TowerSearch
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of income to which each partner contributes one or both of the ingredients of income -- capital or services. Ward v. ThompsonSearch
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Brief any citation in this list with AI Studio
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U. S. 742 their 'agreement, considered as a whole, and by their conduct in execution of its provisions.' Drennen v. LondonSearch
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Cox v. HickmanSearch
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U. S. 102 , 283 U. S. 117 . See Allen v. TrustSearch
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in the family partnership, any more than we said that all family trusts are invalid for tax purposes in Helvering v. CliffordSearch
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as general law, purposes. In the Tower and Lusthaus cases, this Court, applying the principles of Lucas v. EarlSearch
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supra, and Helvering v. HorstSearch
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Merchants Loan & Trust Co. v. SmietankaSearch
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being entrusted with the disposition of partnership funds or of contributing substantial services occurred in Tinkoff v. CommissionerSearch
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Edgington v. FitzmauriceSearch
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been determinative of the question whether a partnership has been formed as between the parties. See, e.g., Drennen v. LondonSearch
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Barker v. KraftSearch
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Zuback v. BakmazSearch
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Kennedy v. MullinsSearch
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appropriate legal criteria are. The Tax Court's decision rested on a misconception of our decision in Commissioner v. TowerSearch
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the nature of that concept was decisive. It is significant that among the cases cited was the leading case of Cox v. HickmanSearch
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simply of the commonplace that no finder of fact can see through the eyes of any other finder of fact. See Texas v. FloridaSearch
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refuse to be precluded from holding the taxpayer to his election to adopt the form of a partnership. Cf. Higgins v. SmithSearch
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Lyeth v. HoeySearch
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Fletcher v. CommissionerSearch
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Hougland v. CommissionerSearch
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U.S. Supreme Court Commissioner v. CulbertsonSearch
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of Commissioner v. TowerSearch
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and Lusthaus v. CommissionerSearch
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Commissioner v. TowerSearch
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Ward v. ThompsonSearch
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Drennen v. LondonSearch
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See Allen v. TrustSearch
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of Lucas v. EarlSearch
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and Helvering v. HorstSearch
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Tinkoff v. CommissionerSearch
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of Cox v. HickmanSearch
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See Texas v. FloridaSearch
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Cf. Higgins v. SmithSearch
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Fletcher v. CommissionerSearch
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United States v. WellsSearch
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