Thompson v. Commissioner of Internal Revenue. Couse v. Commissioner of Internal Revenue

KALODNER, Circuit Judge.

These appeals involve certain government contracts, awarded to a corporation which later dissolved and whose principal stockholder paid a capital gains tax on the value of the contracts (estimated profits) in excess of his basis in the assets of the corporation and then contributed his interest to a partnership later formed. The question presented is whether the partnership may use the value of the contracts as thus determined as a' basis for amortization deductions. • The Tax Court held that it could not. 1952, 18 T.C. 361. Taxpayers petitioned this Court for a review…