The usual type of family partnership has the taxpayer operating or organizing a business, and giving or selling a portion of that business to his wife or children. The aim of the taxpayer is to divide his income among members of the family group. The profits are thus taxed to two or more individuals, rather than to the taxpayer alone. Recognition of these family partnerships for federal income tax purposes is just one aspect of the family income problem.
Yale A. Barkan,
FAMILY PARTNERSHIPS UNDER THE INCOME TAX,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol44/iss2/2