Shaheen v. Commissioner
United States Tax Court
Petitioners received a partnership interest from B and J in exchange for discharging B and J's indebtedness to petitioners. Held, the basis of a partnership interest received in exchange for the cancellation of indebtedness is limited to the fair market value of the interest at the time acquired, unless such interest has no ascertainable fair market value, in which case the basis for such interest is the face amount of the indebtedness discharged.
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Petitioners received a partnership interest from B and J in exchange for discharging B and J's indebtedness to petitioners. Held, the basis of a partnership interest received in exchange for the cancellation of indebtedness is limited to the fair market value of the interest at the time acquired, unless such interest has no ascertainable fair market value, in which case the basis for such interest is the face amount of the indebtedness discharged. Secs. 742, 1012, I.R.C. 1954. Held further, petitioners failed to establish the fair market value of the partnership interest and failed to show…
1Opinion of the Court
GEORGE A. SHAHEEN and EDITH A. SHAHEEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Shaheen v. Commissioner
Docket No. 622-80.
United States Tax Court
T.C. Memo 1982-445; 1982 Tax Ct. Memo LEXIS 302; 44 T.C.M. (CCH) 694; T.C.M. (RIA) 82445;
August 3, 1982.
Petitioners received a partnership interest from B and J in exchange for discharging B and J's indebtedness to petitioners. Held, the basis of a partnership interest received in exchange for the cancellation of indebtedness is limited to the fair market value of the interest at the time acquired, unless such interest has no…
2Cases cited10 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Strong v. CommissionerUnited States Tax Court · 1976
- Roccaforte v. CommissionerUnited States Tax Court · 1981
- Commissioner of Internal Revenue v. SpreckelsCourt of Appeals for the Ninth Circuit · 1941
5 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Litzenberg v. CommissionerUnited States Tax Court · 1988