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SCHNEER v. COMMISSIONER

United States Tax Court (1991) | 97 T.C. 643

4 min read

TL;DR: An attorney joined a new law partnership, agreeing to pool all his income. The court held that fees he received from his former firm for work done after he joined the new partnership were properly treated as partnership income, not an individual anticipatory assignment of income.

Legal Significance: Establishes that income earned by a partner from outside activities can be treated as partnership income, avoiding the assignment of income doctrine, if earned pursuant to a pre-existing partnership agreement and from activities similar to the partnership's business.