Woody v. Commissioner
United States Tax Court
1. Petitioner and his partner each had a 50 per cent interest in a partnership engaged in the furniture business which reported sales on the installment basis. Petitioner sold his interest in the partnership, including his interest in outstanding installment obligations, to his partner.
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1. Petitioner and his partner each had a 50 per cent interest in a partnership engaged in the furniture business which reported sales on the installment basis. Petitioner sold his interest in the partnership, including his interest in outstanding installment obligations, to his partner. This transaction resulted in a disposition of the petitioner's installment obligations within the meaning of section 44 (d) of the Internal Revenue Code, and the petitioner realized gain thereon as computed under that section. 2. Ordinary and necessary business expenses incurred in operation of a farm for…
1Opinion of the Court
OPINION.
Arundell, Judge:
The first issue arises from the following facts: During the years 1943 through 1945, the petitioner and another, doing business as partners, made installment sales of merchandise which they reported under the installment basis provisions of section 44 (a)1 of the Internal Revenue Code. On May 31, 1946, the balance of the installment obligations totaled $47,154.56, of which $17,958.51 represented unrealized gross profits from the installment sales. On May 31,1946, the petitioner disposed of his interest in the installment obligations by selling his partnership interest…
2Cases cited14 opinions
- Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Helvering v. SmithCourt of Appeals for the Second Circuit · 1937
- Swiren v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1950
9 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Woodbury v. CommissionerUnited States Tax Court · 1967
- Nelson v. CommissionerUnited States Tax Court · 1952
- Bunnel v. CommissionerUnited States Tax Court · 1968
- Beus v. CommissionerUnited States Tax Court · 1957
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