Legal Opinion

Butler v. Commissioner

United States Tax Court

Decided May 23, 1966No. Docket No. 2759-64Published

The conveyance by one of petitioners of a one-half interest in his accounting practice to another with whom he formed a partnership for the practice of accounting resulted in capital gain to the extent that the amount received exceeds petitioner's basis in the assets sold, the portion of the payment in excess of that allocable to the tangible assets transferred to the partnership being in payment for one-half of the business' goodwill.

1Opinion of the Court

Hoyt Butler and Virginia W. Butler, Petitioners, v. Commissioner of Internal Revenue, Respondent

Butler v. Commissioner

Docket No. 2759-64

United States Tax Court

46 T.C. 280; 1966 U.S. Tax Ct. LEXIS 97;

May 23, 1966, Filed

Decision will be entered for petitioner.

The conveyance by one of petitioners of a one-half interest in his accounting practice to another with whom he formed a partnership for the practice of accounting resulted in capital gain to the extent that the amount received exceeds petitioner's basis in the assets sold, the portion of the payment in excess of that allocable to the…

2Cases cited8 opinions

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  3. Horton v. CommissionerUnited States Tax Court · 1949
  4. Watson v. CommissionerUnited States Tax Court · 1960
  5. O'Rear v. CommissionerUnited States Board of Tax Appeals · 1933

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