Ledoux v. Commissioner
United States Tax Court
Petitioner sold his 25-percent interest to other partners. Held, a part of the sales proceeds received by petitioner is attributable to unrealized receivables (sec. 751(a) and (c), I.R.C. 1954), and therefore must be characterized as ordinary income.
1Opinion of the Court
Sterrett, Judge-.
By statutory notice dated May 16, 1978, respondent determined deficiencies in petitioners’ Federal income taxes as follows:
TYE Dec. 31— Deficiency
1972. $16,773.86
1973. 16,246.07
1974. 16,016.48
After concessions, the sole issue remaining for our decision is whether any portion of the amount received by petitioner John W. Ledoux pursuant to an agreement for the sale of a partnership interest was attributable to an unrealized receivable of the partnership and thus was required to be characterized as ordinary income under section 751,1.R.C. 1954.
FINDINGS OF FACT
Some of the facts…
2Cases cited16 opinions
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