2018 - 07/09

A business arrangement didn’t rise to the level of a partnership. The U.S. Tax Court ruled that a husband and wife, who had a loose business arrangement with another couple, failed to prove the existence of a partnership under the criteria established by the court. The two couples formed a mortgage business that the court said “was run very informally.” They wanted it to be considered a partnership so they’d only be taxed on their distributive shares of the entity’s income. But the court found it wasn’t properly classified. (TC Memo 2018-102)