Siller Bros. v. Commissioner
United States Tax Court
P and L-P were 50-percent partners in Tri-Eagle Co. P purchased L-P's interest, resulting in a liquidation of the partnership. P continued to carry on the partnership's business without interruption, including the business use of Tri-Eagle's investment credit property. P treated the transaction as a purchase of 50-percent of Tri-Eagle's assets when, in fact, it was a purchase of L-P's 50-percent interest in Tri-Eagle's assets.
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P and L-P were 50-percent partners in Tri-Eagle Co. P purchased L-P's interest, resulting in a liquidation of the partnership. P continued to carry on the partnership's business without interruption, including the business use of Tri-Eagle's investment credit property. P treated the transaction as a purchase of 50-percent of Tri-Eagle's assets when, in fact, it was a purchase of L-P's 50-percent interest in Tri-Eagle's assets. P thus incorrectly transferred Tri-Eagle's basis in its assets to its books and continued to depreciate them using the same lives and methods used by Tri-Eagle. In…
1Opinion of the Court
Siller Brothers, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Siller Bros. v. Commissioner
Docket No. 4051-84
United States Tax Court
89 T.C. 256; 1987 U.S. Tax Ct. LEXIS 112; 89 T.C. No. 22;
August 11, 1987. August 10, 1987, Filed
Decision will be entered under Rule 155.
P and L-P were 50-percent partners in Tri-Eagle Co. P purchased L-P's interest, resulting in a liquidation of the partnership. P continued to carry on the partnership's business without interruption, including the business use of Tri-Eagle's investment credit property. P treated the transaction as a purchase of…
2Cases cited8 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
- Moradian v. CommissionerUnited States Tax Court · 1969
- Southern v. CommissionerUnited States Tax Court · 1986
- Charles L. Long and Ruth S. Long v. United StatesCourt of Appeals for the Sixth Circuit · 1981
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