Legal Opinion

Frankfort v. Commissioner

United States Tax Court

Decided April 29, 1969No. Docket No. 1504-67PublishedCited by 7 opinions

Held, certain amounts paid by T to his widowed mother in accordance with a partnership agreement previously entered into with his father constituted "unrealized receivables," secs. 736 and 751, I.R.C. 1954, and were therefore deductible.

1Opinion of the Court

OPINION

Raum, Judge:

We are again faced with the “distressingly complex and confusing” provisions of subchapter K, David A. Fowman, 41 T.C. 535, 551 fn. 9, affirmed 352 F. 2d 466 (C.A. 3), and our task has not been lightened by petitioners’ various alternative arguments which were not developed with clarity in their briefs. However, we think that petitioners are entitled to prevail by reason of the provisions relating to “unrealized receivables” in sections 736 and 751, set forth in the margin below.2

At the date of Fred, Senior’s death, the partnership had already performed the services…

2Cases cited4 opinions

  1. Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
  2. Foxman v. CommissionerUnited States Tax Court · 1964
  3. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1939
  4. Harry C. v. United StatesUnited States Court of Claims · 1967

3Cited by7 opinions

  1. Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
  2. De Marco v. CommissionerUnited States Tax Court · 1986
  3. Barrett v. CommissionerUnited States Tax Court · 1992
  4. Boland v. CommissionerUnited States Tax Court · 1972
  5. De Marco v. CommissionerUnited States Tax Court · 1986

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