Legal Opinion
Mark IV Pictures, Inc. v. Commissioner
Court of Appeals for the Eighth Circuit
Decided July 13, 1992No. 91-2063PublishedCited by 2 opinions
1Opinion of the Court
JOHN R. GIBSON, Circuit Judge.
Mark IV Pictures, Inc., Heartland Productions, Inc., Russell S. Doughten Jr. and Gertrude S. Doughten appeal from a decision of the tax court1 upholding the determination of the Commissioner of the Internal Revenue that they received partnership interests in exchange for performing services rather than giving property, and that the fair market value of those interests constituted income in the years 1980, 1981 and 1982. On appeal, the taxpayers argue that the tax court erred in concluding that: *671(1) the general partners received partnership interests in exchange…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- United States v. William D. Frazell and Martha T. FrazellCourt of Appeals for the Fifth Circuit · 1964
- Alexis M. Hawkins and Rosemary K. Hawkins v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- William G. Campbell Norma T. Campbell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
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3Cited by2 opinions
- Johnston v. CommissionerUnited States Tax Court · 1995
- Mark IV Pictures, Inc. v. Commissioner of Internal Revenue, Russell S. Doughten, Jr. & Gertrude S. Doughten v. Commissioner of Internal Revenue, Heartland Productions, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992