Busche v. Commissioner
United States Tax Court
Petitioner and his partner transferred the partnership business and assets to a corporation which they controlled and then liquidated the partnership. Held, deduction of any loss sustained by petitioner upon the transaction is prohibited by section 24 (b) (1) (B) of the Internal Revenue Code of 1939.
1Opinion of the Court
Fritz Busche, Petitioner, v. Commissioner of Internal Revenue, Respondent
Busche v. Commissioner
Docket No. 39351
United States Tax Court
23 T.C. 709; 1955 U.S. Tax Ct. LEXIS 260;
January 26, 1955, Filed
Decision will be entered for the respondent.
Petitioner and his partner transferred the partnership business and assets to a corporation which they controlled and then liquidated the partnership. Held, deduction of any loss sustained by petitioner upon the transaction is prohibited by section 24 (b) (1) (B) of the Internal Revenue Code of 1939.
Harold E. Smith, Esq., for the petitioner.
Henry F. Day,…
Also in this document: Dissent.
2Cases cited5 opinions
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
- Western Transmission Corp. v. CommissionerUnited States Tax Court · 1952
- Walnut Street Co. v. GlennDistrict Court, W.D. Kentucky · 1948
- Busche v. CommissionerUnited States Tax Court · 1955