Estate of Skaggs v. Commissioner
United States Tax Court
Held, unless a timely election was made under sec. 754, I.R.C. 1954, the bases of the assets of a California husband-wife partnership were not adjusted on the death of the husband under sec. 1014(a) and (b)( 6), I.R.C. 1954, even though the bases of the interests of the respective partners were adjusted and both the deceased husband's interest and the surviving wife's interest were administered pursuant to State law under the supervision of the local superior court.
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Held, unless a timely election was made under sec. 754, I.R.C. 1954, the bases of the assets of a California husband-wife partnership were not adjusted on the death of the husband under sec. 1014(a) and (b)( 6), I.R.C. 1954, even though the bases of the interests of the respective partners were adjusted and both the deceased husband's interest and the surviving wife's interest were administered pursuant to State law under the supervision of the local superior court. Held, further, a purported election under sec. 754, I.R.C. 1954, to have the bases of the assets of the partnership adjusted for…
1Opinion of the Court
Estate of Ernest D. Skaggs, Deceased, Carolyn C. Fike, Executrix, and Carolyn C. Fike, Formerly Carolyn C. Skaggs, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Skaggs v. Commissioner
Docket No. 6546-78
United States Tax Court
75 T.C. 191; 1980 U.S. Tax Ct. LEXIS 33;
October 30, 1980, Filed
Decision will be entered for the respondent.
Held, unless a timely election was made under sec. 754, I.R.C. 1954, the bases of the assets of a California husband-wife partnership were not adjusted on the death of the husband under sec. 1014(a) and (b)( 6), I.R.C. 1954, even though the…
2Cases cited30 opinions
- Reaver v. CommissionerUnited States Tax Court · 1964
- Foxman v. CommissionerUnited States Tax Court · 1964
- Bayley v. CommissionerUnited States Tax Court · 1960
- Peter Mamula and Dorothy R. Mamula v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
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