Jackson Inv. Co. v. Commissioner
United States Tax Court
Payments were made by a partnership to a retiring partner in liquidation of her partnership interest, and an amount was paid for goodwill, even though the partnership agreement was silent regarding goodwill. Held, the payment for goodwill was within the purview of sec. 736(a)(2), I.R.C. 1954, and was deductible by the partnership.
1Opinion of the Court
OPINION
Forrester, Judge:
All of the facts have been stipulated and are so found.
Respondent has determined deficiencies in income taxes as follows:
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The sole issue now remaining before us is whether certain payments made by Carter Company Contractors and Developers (a partnership formerly known as George W. Carter Co., and hereinafter sometimes referred to as Partnership) to a retiring partner, were properly deductible from the gross income of Partnership when said payments were made in 1956,1957, and 1958.
On September 14, 1950, Jackson Investment Co., a California corporation, West…
Also in this document: Concurrence.
2Cases cited4 opinions
- Miller v. RobertsonSupreme Court of the United States · 1924
- Foxman v. CommissionerUnited States Tax Court · 1964
- Smith v. CommissionerUnited States Tax Court · 1962
- V. Zay Smith, and Ida Smith v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
3Cited by10 opinions
- Kresser v. CommissionerUnited States Tax Court · 1970
- Cooney v. CommissionerUnited States Tax Court · 1975
- Commissioner of Internal Revenue v. Jackson Investment Company, Commissioner of Internal Revenue v. West Shore CompanyCourt of Appeals for the Ninth Circuit · 1965
- Cooney v. CommissionerUnited States Tax Court · 1975
- Jackson Inv. Co. v. CommissionerUnited States Tax Court · 1964
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