Hoagland v. Commissioner
United States Tax Court
The petitioners received payments in settlement of a suit in which they alleged that a partnership existed between themselves and third parties with respect to certain land. In the settlement agreement, the payments were designated as a "finder's fee."
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The petitioners received payments in settlement of a suit in which they alleged that a partnership existed between themselves and third parties with respect to certain land. In the settlement agreement, the payments were designated as a "finder's fee." Held: (1) Extrinsic evidence is admissible to determine whether the payments represented a finder's fee or payment for the petitioners' interests in the partnership; 1327 (2) A partnership existed with respect to the land; and (3) The payments are entitled to long-term capital gain treatment as the land held by the partnership was not held…
1Opinion of the Court
Kenneth C. Hoagland and Eathyl L. Hoagland v. Commissioner. Bob Vincent and Louise F. Vincent v. Commissioner.
Hoagland v. Commissioner
Docket Nos. 104-68, 116-68.
United States Tax Court
T.C. Memo 1971-310; 1971 Tax Ct. Memo LEXIS 21; 30 T.C.M. (CCH) 1326; T.C.M. (RIA) 71310;
December 8, 1971, Filed
The petitioners received payments in settlement of a suit in which they alleged that a partnership existed between themselves and third parties with respect to certain land. In the settlement agreement, the payments were designated as a "finder's fee."
Held: (1) Extrinsic evidence is admissible to…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Malat v. RiddellSupreme Court of the United States · 1966
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
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