Dolese v. Commissioner
United States Tax Court
An individual (R) and his wholly owned corporation (D) caused a partnership (P), in which R held a 49-percent interest and D a 51-percent interest, to distribute a 160-acre tract of land in two tracts (of approximate equal value but not of equal size) to them in ownership percentages disproportionate to their respective partnership interests.
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An individual (R) and his wholly owned corporation (D) caused a partnership (P), in which R held a 49-percent interest and D a 51-percent interest, to distribute a 160-acre tract of land in two tracts (of approximate equal value but not of equal size) to them in ownership percentages disproportionate to their respective partnership interests. As a result of the distribution, R had a 76-percent interest in tract I and a 24-percent interest in tract II; D had a 24-percent interest in tract I and a 76-percent interest in tract II. Immediately following the distribution (which admittedly was done…
1Opinion of the Court
Jacobs, Judge:*
Respondent determined the following deficiencies in petitioners’ Federal income tax:
Year Deficiency
$57,455.12 to
151,077.00 I>
This case involves the distribution of two tracts of land by a partnership to its two partners (an individual and his wholly owned corporation) followed by a partial gift/partial sale of the tracts to Oklahoma City (hereinafter sometimes referred to as the city). The distribution of each tract was disproportionate to the partners’ interests in the partnership, and was made for the purpose of adjusting the partners’ ownership interests in the land prior to…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Whipple v. CommissionerSupreme Court of the United States · 1963
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
16 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Skripak v. CommissionerUnited States Tax Court · 1985
- Goldstein v. CommissionerUnited States Tax Court · 1987
- Roger M. Dolese and Susan B. Dolese v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1987
- Serdar v. CommissionerUnited States Tax Court · 1986
- Weitz v. CommissionerUnited States Tax Court · 1989
11 more not listed; retrieve them via the Exa API.