Woodbury v. Commissioner
United States Tax Court
Held: 1. Reallocation of partnership income determined on the basis of services rendered and respective capital interests of the partners. 2. Income from the sale of certain cattle was constructively received in 1958. 3. In 1960 the partnership made a nontaxable exchange of cattle under sec. 1031(a), I.R.C. 1954. 4. Petitioners are not liable for negligence penalties.
1Opinion of the Court
Leo A. Woodbury, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Woodbury v. Commissioner
Docket Nos. 4352-65, 4353-65, 4354-65
United States Tax Court
49 T.C. 180; 1967 U.S. Tax Ct. LEXIS 11;
December 12, 1967, Filed
Decisions will be entered under Rule 50.
Held: 1. Reallocation of partnership income determined on the basis of services rendered and respective capital interests of the partners.
2. Income from the sale of certain cattle was constructively received in 1958.
3. In 1960 the partnership made a nontaxable exchange of cattle under sec. 1031(a), I.R.C. 1954.
4.…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. OwensSupreme Court of the United States · 1939
- Woodbury v. CommissionerUnited States Tax Court · 1967
- United States v. PfisterCourt of Appeals for the Eighth Circuit · 1953
- James Alderson, Surviving Husband and Estate of Clarissa E. Alderson, Deceased, James Alderson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
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