Silling v. Commissioner
United States Tax Court
Petitioner purchased his partner's interest in their partnership and thereafter continued the operation of the business as a sole proprietorship. The purchase price was determined upon the basis of the estimated profits to be derived from the performance of certain contracts on which the firm was then engaged.
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Petitioner purchased his partner's interest in their partnership and thereafter continued the operation of the business as a sole proprietorship. The purchase price was determined upon the basis of the estimated profits to be derived from the performance of certain contracts on which the firm was then engaged. Held, although these contracts had a zero basis in the hands of the partnership, petitioner is entitled to allocate the purchase price of his partner's interest to such contracts and to amortize the basis thereby established in computing the profits realized on their performance by him…
1Opinion of the Court
C. E. Silling, Sr., and Marian R. Silling, Petitioners, v. Commissioner of Internal Revenue, Respondent
Silling v. Commissioner
Docket No. 53539
United States Tax Court
27 T.C. 701; 1957 U.S. Tax Ct. LEXIS 279;
January 23, 1957, Filed
Decision will be entered under Rule 50.
Petitioner purchased his partner's interest in their partnership and thereafter continued the operation of the business as a sole proprietorship. The purchase price was determined upon the basis of the estimated profits to be derived from the performance of certain contracts on which the firm was then engaged. Held, although…
2Cases cited13 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Hill v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1930
- Thompson v. CommissionerUnited States Tax Court · 1954
- Risko v. CommissionerUnited States Tax Court · 1956
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