Merrill v. Commissioner
United States Tax Court
Petitioner, a general partner in a New York limited partnership, with a fixed term ended December 31, 1939, was permitted to retire as of March 31, 1939. On March 30, 1940, petitioner and the firm executed an agreement whereby in consideration of certain further payments by the petitioner, mutual releases were exchanged and petitioner was assigned his pro rata share of recoveries on certain doubtful but unliquidated accounts as of March 30, 1940. On his Federal income tax…
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Petitioner, a general partner in a New York limited partnership, with a fixed term ended December 31, 1939, was permitted to retire as of March 31, 1939. On March 30, 1940, petitioner and the firm executed an agreement whereby in consideration of certain further payments by the petitioner, mutual releases were exchanged and petitioner was assigned his pro rata share of recoveries on certain doubtful but unliquidated accounts as of March 30, 1940. On his Federal income tax return for 1940 petitioner claimed as an ordinary loss the sum of $ 103,457.84 in connection with his participation as a…
1Opinion of the Court
Joseph L. Merrill, Petitioner, v. Commissioner of Internal Revenue, Respondent
Merrill v. Commissioner
Docket No. 8190
United States Tax Court
9 T.C. 291; 1947 U.S. Tax Ct. LEXIS 113;
September 9, 1947, Promulgated
Decision will be entered for the respondent.
Petitioner, a general partner in a New York limited partnership, with a fixed term ended December 31, 1939, was permitted to retire as of March 31, 1939. On March 30, 1940, petitioner and the firm executed an agreement whereby in consideration of certain further payments by the petitioner, mutual releases were exchanged and petitioner was…
2Cases cited8 opinions
- Helvering v. GowranSupreme Court of the United States · 1937
- Lyeth v. HoeySupreme Court of the United States · 1938
- Blodgett v. SilbermanSupreme Court of the United States · 1928
- Case v. BeauregardSupreme Court of the United States · 1879
- Ford v. Comm'rUnited States Tax Court · 1946
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