https://www.taxtmi.com/caselaws?id=69783 Conversion of a proprietary business into a partnership was treated as a transfer of property for gift-tax purposes because partnership rights were granted in that business. The transfer was held to be a taxable gift since the incoming partners' nominal capital contribution, without real business experience or substantial services, was not adequate consideration in money or money's worth. The valuation of the gift was, however, modified because higher allowances for managerial remuneration and interest on capital were justified on the facts, reducing the taxable value. en-us Wed, 24 Sep 1980 00:00:00 +0530 Tue, 12 Apr 2011 10:50:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69783 Conversion of a proprietary business into a partnership was treated as a transfer of property for gift-tax purposes because partnership rights were granted in that business. The transfer was held to be a taxable gift since the incoming partners' nominal capital contribution, without real business experience or substantial services, was not adequate consideration in money or money's worth. The valuation of the gift was, however, modified because higher allowances for managerial remuneration and interest on capital were justified on the facts, reducing the taxable value. Case-Laws Income Tax Wed, 24 Sep 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69783