Long v. Commissioner
United States Tax Court
Petitioners Long and Center were 50-percent owners in a Texas partnership, L, and a Georgia joint venture, V, with essentially the same group of taxpayers owning the remaining 50 percent. Both L and V's principal asset at the date of the exchange was mortgaged rental real estate located in or near Atlanta, Ga.
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Petitioners Long and Center were 50-percent owners in a Texas partnership, L, and a Georgia joint venture, V, with essentially the same group of taxpayers owning the remaining 50 percent. Both L and V's principal asset at the date of the exchange was mortgaged rental real estate located in or near Atlanta, Ga. Petitioners exchanged their 50-percent interest in L for the other 50-percent interest in V with the result that they owned 100 percent of V and none of L. Held, the exchange of partnership interests qualifies as a like-kind exchange under sec. 1031(a), I.R.C. 1954. Held, further, the…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies of $91,323 and $10,658 for the calendar years 1975 and 1976, respectively, in the Federal income tax of Arthur and Selma Long and deficiencies in the amount of $153,443 and $4,761 for the calendar years 1975 and 1976, respectively, in the Federal income tax of Dave and Bernette Center.
After concessions by the parties, the issues for decision are: (1) Whether the exchange of an interest in a Texas general partnership for an interest in a Georgia joint venture qualifies for nonrecognition treatment under section 1031(a), I.R.C. 1954;1 (2) if the…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
18 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Leahy v. CommissionerUnited States Tax Court · 1986
- Norman J. And Beverly G. Magneson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Bertoli v. CommissionerUnited States Tax Court · 1994
- Garcia v. CommissionerUnited States Tax Court · 1983
- Pappas v. CommissionerUnited States Tax Court · 1982
10 more not listed; retrieve them via the Exa API.