Legal Opinion

McDougal v. Commissioner

United States Tax Court

Decided August 29, 1974No. Docket Nos. 534-72, 535-72Published

As compensation for services rendered, the McDougals gave McClanahan a 50-percent interest in the capital and profits of a joint venture to which the McDougals contributed appreciated property. Held, that the McDougals recognized gain to the extent that the value of a half interest in the contributed property exceeded the McDougal's adjusted basis in the aforesaid half interest.

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As compensation for services rendered, the McDougals gave McClanahan a 50-percent interest in the capital and profits of a joint venture to which the McDougals contributed appreciated property. Held, that the McDougals recognized gain to the extent that the value of a half interest in the contributed property exceeded the McDougal's adjusted basis in the aforesaid half interest. Held, further, that in determining the joint venture's basis in the contributed property, it is to be deemed that the McDougals transferred a half interest in the said property to McClanahan and thereafter, in concert…

1Opinion of the Court

F. C. and Frankie McDougal, Petitioners v. Commissioner of Internal Revenue, Respondent; Gilbert and Jackie McClanahan, Petitioners v. Commissioner of Internal Revenue, Respondent

McDougal v. Commissioner

Docket Nos. 534-72, 535-72

United States Tax Court

62 T.C. 720; 1974 U.S. Tax Ct. LEXIS 52; 62 T.C. No. 78;

August 29, 1974, Filed

Decisions will be entered under Rule 155.

As compensation for services rendered, the McDougals gave McClanahan a 50-percent interest in the capital and profits of a joint venture to which the McDougals contributed appreciated property. Held, that the McDougals…

2Cases cited12 opinions

  1. Commissioner v. DubersteinSupreme Court of the United States · 1960
  2. Bogardus v. CommissionerSupreme Court of the United States · 1937
  3. United States v. DavisSupreme Court of the United States · 1962
  4. Luna v. CommissionerUnited States Tax Court · 1964
  5. Hoffman v. CommissionerUnited States Tax Court · 1943

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