Hawaiian Freight Forwarders, Ltd. v. Commissioner
United States Tax Court
A, B, and C were partners in a freight forwarding business with interests approximating 49%, 35% and 15%, respectively. A and B reached an agreement with an outside party for the transfer of the business and its assets, exclusive of C's interest, to a newly organized corporation.
Read the full summary
A, B, and C were partners in a freight forwarding business with interests approximating 49%, 35% and 15%, respectively. A and B reached an agreement with an outside party for the transfer of the business and its assets, exclusive of C's interest, to a newly organized corporation. An agreement was then reached with C for the payment to him of an amount which the parties had agreed represented his interest in the assets of the business, including good will, and in the accumulated profits since the beginning of the year. Petitioner corporation was then formed and in exchange for its entire issue…
1Opinion of the Court
Hawaiian Freight Forwarders, Ltd., Petitioner, v. Commissioner of Internal Revenue, Respondent
Hawaiian Freight Forwarders, Ltd. v. Commissioner
Docket No. 19283
United States Tax Court
15 T.C. 35; 1950 U.S. Tax Ct. LEXIS 119;
July 31, 1950, Promulgated
Decision will be entered under Rule 50.
A, B, and C were partners in a freight forwarding business with interests approximating 49%, 35% and 15%, respectively. A and B reached an agreement with an outside party for the transfer of the business and its assets, exclusive of C's interest, to a newly organized corporation. An agreement was then reached…
2Cases cited3 opinions
- E. T. Renfro Drug Co. v. CommissionerUnited States Tax Court · 1948
- Ransohoffs, Inc. v. CommissionerUnited States Tax Court · 1947
- Hawaiian Freight Forwarders, Ltd. v. CommissionerUnited States Tax Court · 1950