Meyer v. Commissioner
United States Tax Court
In 1946 petitioners, Leon and Lucile, husband and wife, who were coowners of a partnership caused the organization of a corporation, Jewelry, to which they transferred the partnership assets in exchange for the assumption of the partnership liabilities and the issuance to them in equal amounts of Jewelry's capital stock (designated as class A stock) and notes totaling in par and face value the net value of the partnership assets so transferred.
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In 1946 petitioners, Leon and Lucile, husband and wife, who were coowners of a partnership caused the organization of a corporation, Jewelry, to which they transferred the partnership assets in exchange for the assumption of the partnership liabilities and the issuance to them in equal amounts of Jewelry's capital stock (designated as class A stock) and notes totaling in par and face value the net value of the partnership assets so transferred. In 1947 the notes were capitalized by the issuance to Leon and Lucile of class B stock of Jewelry which had at that time voting rights and some…
1Opinion of the Court
Respondent originally determined a deficiency in the income tax liability of petitioner Leon R. Meyer (hereinafter sometimes referred to as Leon) for the year 1959 in the sum of $40,191.55 and a deficiency in the income tax liability of petitioner Lueile H. Meyer (hereinafter isometim.es referred to as Lueile) for the year 1959 in the sum of $17,402.09.
The statement attached to the notice of deficiency addressed to Leon indicated the increase of his taxable income as disclosed in his return by the addition thereto of the following items: (1) Capital gains totaling $39,766.39, realized from…
2Cases cited43 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Flanagan v. HelveringCourt of Appeals for the D.C. Circuit · 1940
38 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- Dellacroce v. CommissionerUnited States Tax Court · 1984
- Hoeme v. CommissionerUnited States Tax Court · 1974
- Estate of Goodall v. CommissionerCourt of Appeals for the Eighth Circuit · 1968
- Guest v. CommissionerUnited States Tax Court · 1981
- Lewis v. CommissionerUnited States Tax Court · 1966
42 more not listed; retrieve them via the Exa API.