Barron v. Commissioner
United States Tax Court
64 T.C.M. 1034 (1992)
- Written by Eric Miller, JD
Facts
Robert Barron (plaintiff), Paul Sanders, Earl Hermann, and B. C. LeClerc entered an oral agreement to conduct business activities, mainly involving wood products, under the name B & B. When Barron applied for a business license, he indicated that B & B was a sole proprietorship. Barron also took out a workers’-compensation policy for B & B in his own name. However, each of the four parties contributed funds to the business, and a collective bank account was created with all the parties’ signatures. B & B did not file as a partnership. The Commissioner of Internal Revenue (the commissioner) (defendant) determined that B & B was Barron’s sole proprietorship and that Barron had failed to account for its taxable income. Barron challenged this determination in the United States Tax Court, asserting that B & B was a partnership and that as one of four partners, he was required to report only one-fourth of its taxable income.
Rule of Law
Issue
Holding and Reasoning (Nameroff, J.)
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