Legal Opinion

Pappas v. Commissioner

United States Tax Court

Decided June 17, 1982No. Docket Nos. 6397-80, 1219-81Published

Petitioner exchanged a general partnership interest in Parkview and then, together with those with whom he exchanged the interest, formed a limited partnership (Kenosha). Kenosha was formed by petitioner's contributing his services for his 2-percent general partnership interest and the others contributing the partnership interest in Parkview that they had acquired from petitioner for their 98-percent limited partnership interest.

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Petitioner exchanged a general partnership interest in Parkview and then, together with those with whom he exchanged the interest, formed a limited partnership (Kenosha). Kenosha was formed by petitioner's contributing his services for his 2-percent general partnership interest and the others contributing the partnership interest in Parkview that they had acquired from petitioner for their 98-percent limited partnership interest. Held, the substance of the transactions coincides with the form, and gain from the exchange of general partnership interests need not be recognized under sec.…

1Opinion of the Court

Peter N. Pappas, Petitioner v. Commissioner of Internal Revenue, Respondent; Peter N. Pappas and Marlene Pappas, Petitioners v. Commissioner of Internal Revenue, Respondent

Pappas v. Commissioner

Docket Nos. 6397-80, 1219-81

United States Tax Court

78 T.C. 1078; 1982 U.S. Tax Ct. LEXIS 79; 78 T.C. No. 77;

June 17, 1982, Filed

Decisions will be entered under Rule 155.

Petitioner exchanged a general partnership interest in Parkview and then, together with those with whom he exchanged the interest, formed a limited partnership (Kenosha). Kenosha was formed by petitioner's contributing his services for…

2Cases cited9 opinions

  1. D. Ginsberg & Sons, Inc. v. PopkinSupreme Court of the United States · 1932
  2. Gulfstream Land & Development Corp. v. CommissionerUnited States Tax Court · 1979
  3. Marian Essenfeld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  4. Essenfeld v. CommissionerUnited States Tax Court · 1961
  5. Estate of Rollin E. Meyer, Sr., Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974

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