Baker Commodities, Inc. v. Commissioner
United States Tax Court
In 1961, three brothers transferred their partnership business, consisting of stock in four corporations and real estate, to a corporation owned partly by them and partly by seven employees of the partnership business.
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In 1961, three brothers transferred their partnership business, consisting of stock in four corporations and real estate, to a corporation owned partly by them and partly by seven employees of the partnership business. In consideration for the partnership assets thus acquired, the corporation assumed partnership indebtedness of $ 62,000 and issued a $ 3,150,000, 15-year promissory note to the partnership which required the corporation to make annual payments of interest and principal in the amounts of $ 80,000 and $ 200,000, respectively. Immediately after the transfer, the corporation…
1Opinion of the Court
Baker Commodities, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Baker Commodities, Inc. v. Commissioner
Docket Nos. 1371-65, 5416-65, 5418-65, 5420-65
United States Tax Court
48 T.C. 374; 1967 U.S. Tax Ct. LEXIS 84; 48 T.C. No. 39;
June 23, 1967, Filed
Decisions will be entered under Rule 50.
In 1961, three brothers transferred their partnership business, consisting of stock in four corporations and real estate, to a corporation owned partly by them and partly by seven employees of the partnership business. In consideration for the partnership assets thus acquired, the…
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Malat v. RiddellSupreme Court of the United States · 1966
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- National Lead Co. v. United StatesSupreme Court of the United States · 1920
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
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