Legal Opinion

Estate of Ernest D. Skaggs, Deceased, Carolyn C. Fike, and Carolyn C. Fike, Formerly Carolyn C. Skaggs v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided March 24, 1982No. CA 81-7058PublishedCited by 13 opinions

1Per curiam

Petitioners appeal the Tax Court’s decision that absent a timely election under I.R.C. § 754, the bases of the partnership assets could not be adjusted on the death of a partner under I.R.C. § 1014(a) and (b)(6) until the partnership was terminated. The petitioners contest the Tax Court’s ruling that the death of a partner does not, in and of itself, serve to terminate the partnership for tax purposes.

I. FACTS

Ernest Skaggs, decedent, and Carolyn C. Skaggs, his widow, conducted a farming business as equal partners in a two-member partnership known as the Santa Rita Ranch Company. They owned…

2Cases cited3 opinions

  1. Richard R. Sibla v. Commissioner of Internal Revenue, Robert E. Cooper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  2. Geneva Drive in Theatre, Inc. Las Vegas Theatrical Corp. Concord Theatre Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  3. Estate of Skaggs v. CommissionerUnited States Tax Court · 1980

3Cited by13 opinions

  1. Elliotts, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  2. Atlantic Veneer Corp. v. CommissionerUnited States Tax Court · 1985
  3. Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  4. Estate of Higgins v. CommissionerUnited States Tax Court · 1988
  5. Keller Street Development Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982

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