Goldberg v. Commissioner
United States Tax Court
Decedent, at the time of his death in August 1945, was a member of a partnership which was in the furniture business and used the installment basis in returning its income from installment obligations.
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Decedent, at the time of his death in August 1945, was a member of a partnership which was in the furniture business and used the installment basis in returning its income from installment obligations. The decedent's 30 per cent share in the unrealized gross profits on the installment obligations owing to the partnership at the time of decedent's death was $ 30,168.42. Held, that the $ 30,168.42 in question is includible in decedent's income for the period ending with his death under section 44 (d) of the Internal Revenue Code, no bond having been filed as provided in the concluding part of…
1Opinion of the Court
OPINION.
Black, Judge:
We have but one issue to decide in this proceeding and that is whether or not the death of Meyer Goldberg, who was a member of the partnership of M. Goldberg & Sons, which partnership owned installment obligations at the date of his death, caused a transmission or disposition of those obligations or any interest therein within the meaning of section 44 (d) of the Internal Revenue Code, resulting in taxable income to the decedent or to his estate, no bond having been filed under the provisions of the statute. Section 44 (d) is printed in the margin.1 Petitioners concede…
2Cases cited3 opinions
- Ford v. Comm'rUnited States Tax Court · 1946
- Lehman v. CommissionerUnited States Tax Court · 1946
- Carroll v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1934
3Cited by7 opinions
- Woody v. CommissionerUnited States Tax Court · 1952
- Goldberg's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Dixon v. CommissionerUnited States Tax Court · 1951
- Dixon v. CommissionerUnited States Tax Court · 1951
- Dixon v. CommissionerUnited States Tax Court · 1951
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