Raymond Pearson Motor Co. v. Commissioner of Internal Revenue

For over fifteen years prior to 1946 Raymond Pearson was an automobile dealer in Houston, Texas, handling Ford cars in one division of his business and Lincolns and Mercurys in another. This business was then wholly owned by Raymond Pearson. He handled used cars, parts and accessories, made repairs and rendered related services. In 1939 Raymond Pearson entered into a partnership with his two sons, Raymond Pearson, Jr. and Robertson Pearson under the name of Raymond Pearson and Sons. The partnership agreement recited the partnership purposes to be the handling of Ford tractors and Ferguson farm implements and the financing of the sale of automobiles, particularly those sold by Raymond Pearson. Each partner had a third interest in the business, and profits and losses were to be shared equally.