Legal Opinion

Woody v. Commissioner

United States Tax Court

Decided November 28, 1952No. Docket Nos. 36396, 36397Published

1. Petitioner and his partner each had a 50 per cent interest in a partnership engaged in the furniture business which reported sales on the installment basis. Petitioner sold his interest in the partnership, including his interest in outstanding installment obligations, to his partner.

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1. Petitioner and his partner each had a 50 per cent interest in a partnership engaged in the furniture business which reported sales on the installment basis. Petitioner sold his interest in the partnership, including his interest in outstanding installment obligations, to his partner. This transaction resulted in a disposition of the petitioner's installment obligations within the meaning of section 44 (d) of the Internal Revenue Code, and the petitioner realized gain thereon as computed under that section. 2. Ordinary and necessary business expenses incurred in operation of a farm for…

1Opinion of the Court

Rhett W. Woody and Inez Woody, Petitioners, v. Commissioner of Internal Revenue, Respondent

Woody v. Commissioner

Docket Nos. 36396, 36397

United States Tax Court

19 T.C. 350; 1952 U.S. Tax Ct. LEXIS 30;

November 28, 1952, Promulgated

Decisions will be entered under Rule 50.

1. Petitioner and his partner each had a 50 per cent interest in a partnership engaged in the furniture business which reported sales on the installment basis. Petitioner sold his interest in the partnership, including his interest in outstanding installment obligations, to his partner. This transaction resulted in a disposition…

2Cases cited15 opinions

  1. Davis Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
  2. Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
  3. Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
  4. Helvering v. SmithCourt of Appeals for the Second Circuit · 1937
  5. Swiren v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1950

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