Shunk v. Commissioner
United States Tax Court
The trust estate, taxable as a corporation, sold its assets and business to a partnership composed of the three beneficiaries and two employees who were not beneficiaries. The selling price was the book value of the assets at the close of the fiscal year 1940. No value for good will was carried on the books of the company. The partnership continued the business under the same name.
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The trust estate, taxable as a corporation, sold its assets and business to a partnership composed of the three beneficiaries and two employees who were not beneficiaries. The selling price was the book value of the assets at the close of the fiscal year 1940. No value for good will was carried on the books of the company. The partnership continued the business under the same name. Held, the trust estate transferred good will to the partnership which had a fair market value of $ 110,194.80; held, further, long term notes given to the trust estate had a fair market value equal to their…
1Opinion of the Court
John Q. Shunk, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of Francis R. Shunk, Deceased, John Q. Shunk, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent. Estate of Catherine Fegley, Deceased, John Q. Shunk, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Shunk v. Commissioner
Docket Nos. 9540, 9541, 9542
United States Tax Court
10 T.C. 293; 1948 U.S. Tax Ct. LEXIS 263;
February 17, 1948, Promulgated
Decision will be entered under Rule 50.
The trust estate, taxable as a corporation, sold its assets and business to a partnership…
2Cases cited5 opinions
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Toledo Newspaper Co. v. CommissionerUnited States Tax Court · 1943
- Lawton v. CommissionerUnited States Tax Court · 1946
- Strake Trust v. CommissionerUnited States Tax Court · 1943
- Shunk v. CommissionerUnited States Tax Court · 1948