26 U.S.C. § 191
Repealed. Pub. L. 97–34, title II, § 212(d)(1), Aug. 13, 1981, 95 Stat. 239]
[repealed]
Notes of Decisions
Cited in 14
cases, 1928–1980 · leading case: Alexander v. Comm'r of Internal Revenue, 194 F.2d 921 (5th Cir. 1952).
Alexander v. Comm'r of Internal Revenue, 194 F.2d 921 (5th Cir. 1952). “§ 191 , relating to “Family Partnerships” as follows: “In the case of any partnership interest created by gift, the distributive share of the donee under the partnership agreement shall be includible in his gross income, except to the extent that such share is determined without…”
Found. for San Francisco's Architectural Heritage v. City of San Francisco, 106 Cal. App. 3d 893 (Cal. Ct. App. 1980). “9 Equally without merit is the contention made for the first time at oral argument that the potential tax incentives for preservation afforded by the Tax Reform Act of 1976 ( 26 U.S.C. § 191 ) and the Revenue Act of 1978 were not considered.”
Mathew J. Spiesman, Jr., & Mary Spiesoman v. Comm'r of Internal Revenue, 260 F.2d 940 (9th Cir. 1958). “452], 26 U.S.C.A. § 191 and Section 3797 of the Internal Revenue Code of 1939 [as amended by Section 340(a) of the Revenue Act of 1951, supra], 26 U.”
Toor v. Westover. Toor v. Westover, 200 F.2d 713 (9th Cir. 1953). “2 Although Congress has specifically provided that determinations as to, the *716 validity of a family partnership for tax purposes for any taxable year beginning before January 1, 1951, shall be made as if Section 340(b) of the Revenue Act of 1951, 26 U.S.C.A. § 191 , had not…”
T. M. Stanback, T. M. Stanback & Ada M. Stanback, Fred J. Stanback, Fred J. Stanback & Elizabeth C. Stanback v. Comm'r of Internal Revenue, 271 F.2d 514 (4th Cir. 1959). ““In the case of any partnership interest created by gift, the distributive sharof the donee under the partnership agrement shall be includible in his gross income, except to the extent that such share is determined without allowance of reasonable compensation for services…”
Parker v. Westover, 221 F.2d 603 (9th Cir. 1955). “The Revenue Act of 1951, § 340(b) inserted 26 U.S.C. § 191 , 65 *607 Stat. SllClDSl) 1 2into the Code.”
Forman v. Comm'r of Internal Revenue, 199 F.2d 881 (9th Cir. 1952). “6 In this respect, it might be noted that the three Circuit Court cases just cited were decided after Congress adopted 26 U.S.C.A. § 191 , entitled “Family Partnerships”.”
Broide v. United States, 156 F. Supp. 12 (N.D. Ill. 1957). “Jarecki, supra, and the first question has been found to be particularly applicable to that case.”
Leeb v. Jarecki, 156 F. Supp. 6 (N.D. Ill. 1957). “The Senate Finance Committee Report dealing with this section of the Revenue Act of 1951 states: “Two principles governing attribution of income have long been accepted as basic: (1) income from property is attributable to the owner of the property; (2) income from personal…”
Poggetto v. United States, 193 F. Supp. 688 (N.D. Cal. 1961). “On the other hand, capital is ordinarily a material income-producing factor if the operation of the business requires substantial inventories or a substantial investment in plant, machinery, or other equipment.”
United States v. Kent, 36 F.2d 401 (S.D. Ill. 1929). “§ 3242 (Internal Revenue Law [26 USCA § 191]), whieh Remus was charged with having violated was in force and effect after the enactment of the Willis-Campbell Act (27 USCA §§ 2, 3, 15, 18, 20, 53, 54, 56), reversing the District Court for the Southern District of Ohio, whieh had…”
Stork Restaurant Corp. v. McCampbell, 55 F.2d 687 (S.D.N.Y. 1932). “The plaintiff then alleges on information and belief that on December 22, 1931, prohibition agents under the defendant’s direction entered and took possession of the plaintiff’s premises, made arrests for violation of the National Prohibition Law (27 USCA) and for violation of…”
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