Cagle v. Commissioner
United States Tax Court
Petitioners Jackson E. Cagle, Jr., and Charles L. Webster, Jr., along with John F. Eulich, formed a partnership in 1968 to deal in warehouses, office buildings, and other commercial property.
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Petitioners Jackson E. Cagle, Jr., and Charles L. Webster, Jr., along with John F. Eulich, formed a partnership in 1968 to deal in warehouses, office buildings, and other commercial property. By separate agreement the partnership agreed to pay John F. Eulich d.b.a. the Vantage Co. a management fee in the amount of $ 110,000, of which $ 90,000 was to be paid on or before Dec. 31, 1968. Held, the $ 90,000 payment made in 1968 is not deductible by the partnership and hence the losses distributed by the partnership and reported by petitioners are reduced accordingly since the payment was not…
1Opinion of the Court
Sterrett, Judge:
The respondent determined deficiencies in the Federal income taxes of petitioners Jackson E. Cagle, Jr., and Ann Cagle and petitioners Charles L. Webster, Jr., and Sylvia Webster for their taxable years 1968 in the amounts of $33,218.44 and $14,006.80, respectively. Certain issues not having been raised in the petitions to the Court, the sole issue for determination is whether a $90,000 management fee paid by the partnership Parkway Property Co. to John F. Eulich d.b.a. the Vantage Co. is a deductible expense of the partnership.
FINDINGS OF FACT
Some of the facts have been…
2Cases cited20 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Enoch v. CommissionerUnited States Tax Court · 1972
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
15 more not listed; retrieve them via the Exa API.
3Cited by80 opinions
- Surloff v. CommissionerUnited States Tax Court · 1983
- Thomas v. CommissionerUnited States Tax Court · 1985
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- Goodwin v. CommissionerUnited States Tax Court · 1980
- Hilton v. CommissionerUnited States Tax Court · 1980
75 more not listed; retrieve them via the Exa API.