Long v. Commissioner
United States Tax Court
Petitioners Long and Center were 50-percent owners in a Texas partnership, L, and a Georgia joint venture, V, with essentially the same group of taxpayers owning the remaining 50 percent. Both L and V's principal asset at the date of the exchange was mortgaged rental real estate located in or near Atlanta, Ga.
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Petitioners Long and Center were 50-percent owners in a Texas partnership, L, and a Georgia joint venture, V, with essentially the same group of taxpayers owning the remaining 50 percent. Both L and V's principal asset at the date of the exchange was mortgaged rental real estate located in or near Atlanta, Ga. Petitioners exchanged their 50-percent interest in L for the other 50-percent interest in V with the result that they owned 100 percent of V and none of L. Held, the exchange of partnership interests qualifies as a like-kind exchange under sec. 1031(a), I.R.C. 1954. Held, further, the…
1Opinion of the Court
Arthur E. and Selma Long, Petitioners v. Commissioner of Internal Revenue, Respondent; Dave and Bernette N. Center, Petitioners v. Commissioner of Internal Revenue, Respondent
Long v. Commissioner
Docket Nos. 17522-79, 17528-79
United States Tax Court
77 T.C. 1045; 1981 U.S. Tax Ct. LEXIS 38;
October 29, 1981, Filed
Decisions will be entered under Rule 155.
Petitioners Long and Center were 50-percent owners in a Texas partnership, L, and a Georgia joint venture, V, with essentially the same group of taxpayers owning the remaining 50 percent. Both L and V's principal asset at the date of the exchange…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
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