E. T. Renfro Drug Co. v. Commissioner
United States Tax Court
Where one of three partners sells his partnership interest to the other two partners, who thereby acquire all the partnership assets in equal proportion and the remaining partners then sell substantially all the partnership property to a corporation over 80 per cent of whose stock is owned in equal shares by the remaining partners, held, the income of the partnership during the base period years prior to the withdrawal of one partner can not be included in the base period…
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Where one of three partners sells his partnership interest to the other two partners, who thereby acquire all the partnership assets in equal proportion and the remaining partners then sell substantially all the partnership property to a corporation over 80 per cent of whose stock is owned in equal shares by the remaining partners, held, the income of the partnership during the base period years prior to the withdrawal of one partner can not be included in the base period income of the corporation for excess profits tax purposes. Regulations 112, section 35.740-4, approved.
1Opinion of the Court
E. T. Renfro Drug Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
E. T. Renfro Drug Co. v. Commissioner
Docket No. 12463
United States Tax Court
11 T.C. 994; 1948 U.S. Tax Ct. LEXIS 13;
December 7, 1948, Promulgated
Decision will be entered for the respondent.
Where one of three partners sells his partnership interest to the other two partners, who thereby acquire all the partnership assets in equal proportion and the remaining partners then sell substantially all the partnership property to a corporation over 80 per cent of whose stock is owned in equal shares by the remaining…
2Cases cited2 opinions
- E. T. Renfro Drug Co. v. CommissionerUnited States Tax Court · 1948
- Ransohoffs, Inc. v. CommissionerUnited States Tax Court · 1947