Logourl black
From our private database of 13,800+ case briefs...

Commissioner v. Culbertson

United States Supreme Court
337 U.S. 733 (1949)


Facts

In 1915, Culbertson (plaintiff) and R.S. Coon formed a partnership to run a cattle business. In 1939, Coon desired to dissolve the partnership. Culbertson, who wanted to continue the business, purchased the remaining cattle from Coon and formed a new partnership with his four sons by transferring to them an undivided one-half interest in the cattle herd. In return, the sons issued Culbertson a note, which they eventually paid off with profits from the cattle ranch. The new partnership, Culbertson & Sons, began operation in 1940. At the time, Culbertson’s eldest son lived on the ranch with his wife, where he had worked the previous two years as a foreman for Culbertson and Coon’s partnership. Culbertson’s second son was in college at the time the new partnership was formed and then directly entered the army. He did not render any services for the tax years 1940 and 1941. The two youngest sons were in school and worked on the ranch in the summer. Culbertson and Sons filed a partnership return for 1940 and 1941, and divided income according to each partner’s interest. The Commissioner (defendant) determined that the partnership’s entire income was taxable to Culbertson because his sons were not true partners. The Tax Court sustained the Commissioner’s finding. The Court of Appeals reversed. The United States Supreme Court granted certiorari.

Rule of Law

The rule of law is the black letter law upon which the court rested its decision. To access this section, start your 7-day free trial of Quimbee for Law Students.

Issue

The issue section includes the dispositive legal issue in the case phrased as a question. To access this section, start your 7-day free trial of Quimbee for Law Students.

Holding and Reasoning (Vinson, C.J.)

The holding and reasoning section includes:

  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

To access this section, start your 7-day free trial of Quimbee for Law Students.

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 166,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.