Hensley v. Commissioner
United States Tax Court
T was member of a partnership that constructed an apartment house for a corporation under an F. H. A. commitment. The partnership originally owned most of the stock in the corporation and during the tax year (1952) owned about two-thirds of the stock. After completion of construction T assigned his partnership interest in the stock to his partner in consideration of payment of certain partnership obligations.
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T was member of a partnership that constructed an apartment house for a corporation under an F. H. A. commitment. The partnership originally owned most of the stock in the corporation and during the tax year (1952) owned about two-thirds of the stock. After completion of construction T assigned his partnership interest in the stock to his partner in consideration of payment of certain partnership obligations. Held, T's partnership interest in the stock was a capital asset and his loss upon disposition was subject to statutory limitations upon capital losses. Sec. 117 (a) (1) and (d) (2), I.…
1Opinion of the Court
Carl Hensley and Eloise G. Hensley, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hensley v. Commissioner
Docket No. 60275
United States Tax Court
31 T.C. 341; 1958 U.S. Tax Ct. LEXIS 37;
November 12, 1958, Filed
Decision will be entered for the respondent.
T was member of a partnership that constructed an apartment house for a corporation under an F. H. A. commitment. The partnership originally owned most of the stock in the corporation and during the tax year (1952) owned about two-thirds of the stock. After completion of construction T assigned his partnership interest in the stock…
2Cases cited6 opinions
- Commissioner of Internal Revenue v. ShapiroCourt of Appeals for the Sixth Circuit · 1942
- Commissioner of Internal Revenue v. SmithCourt of Appeals for the Fifth Circuit · 1949
- Edwards v. Hogg (Three Cases)Court of Appeals for the Fifth Circuit · 1954
- Exposition Souvenir Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
- Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1932
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