Legal Opinion

Ledoux v. Commissioner

United States Tax Court

Decided August 10, 1981No. Docket No. 9470-78PublishedCited by 13 opinions

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

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  3. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  4. Danielson v. CommissionerUnited States Tax Court · 1965
  5. Bernard D. Spector v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981

11 more not listed; retrieve them via the Exa API.

3Cited by13 opinions

  1. Warsaw Photographic Associates, Inc. v. CommissionerUnited States Tax Court · 1985
  2. Vaughn v. CommissionerUnited States Tax Court · 1983
  3. Watts v. Comm'rUnited States Tax Court · 2017
  4. Crabtree v. CommissionerUnited States Tax Court · 1984
  5. Ehlert v. CommissionerUnited States Tax Court · 1985

8 more not listed; retrieve them via the Exa API.

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