Legal Opinion

Siller Bros. v. Commissioner

United States Tax Court

Decided August 11, 1987No. Docket No. 4051-84Published

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

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
  3. Moradian v. CommissionerUnited States Tax Court · 1969
  4. Southern v. CommissionerUnited States Tax Court · 1986
  5. Charles L. Long and Ruth S. Long v. United StatesCourt of Appeals for the Sixth Circuit · 1981

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