https://www.taxtmi.com/caselaws?id=11535 Taxable gift claims arising from the introduction of business assets into a partnership require prior determination of the value of assets contributed by each partner and the consideration supporting the arrangement. Differing assumptions about those contributions cannot establish whether a transfer constitutes a deemed gift. The Revenue bears the burden of proving the alleged gift, and the legal issue cannot be conclusively determined without findings on the underlying factual foundation. Fresh consideration is required after properly ascertaining the respective contributions and consideration involved. en-us Thu, 24 Oct 2002 00:00:00 +0530 Thu, 14 Jan 2010 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11535 Taxable gift claims arising from the introduction of business assets into a partnership require prior determination of the value of assets contributed by each partner and the consideration supporting the arrangement. Differing assumptions about those contributions cannot establish whether a transfer constitutes a deemed gift. The Revenue bears the burden of proving the alleged gift, and the legal issue cannot be conclusively determined without findings on the underlying factual foundation. Fresh consideration is required after properly ascertaining the respective contributions and consideration involved. Case-Laws Income Tax Thu, 24 Oct 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11535