Legal Opinion
R. Timmis Ware and Catherine K. Ware v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided September 17, 1990No. 807, Docket 89-4113PublishedCited by 32 opinions
1Opinion of the Court
OAKES, Chief Judge:
R. Timmis Ware appeals a decision of the United States Tax Court, Theodore Tannen-wald, Jr., Judge, entered on April 19, 1989, determining that a portion of a payment received by Ware upon withdrawing from his law partnership was attributable to an “unrealized receivable” and therefore should have been treated as ordinary income rather than as capital gain on Ware’s 1982 income tax return. We affirm.
In 1981, Ware was a partner in the New York City law firm of Rogers, Hoge & Hills when he and another partner, James B. Swire, helped arrange the sale of a pharmaceutical plant…
2Cases cited5 opinions
- Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990
- Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
- Ware v. CommissionerUnited States Tax Court · 1989
- John E. Reed v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1983
3Cited by32 opinions
- Carione v. United StatesDistrict Court, E.D. New York · 2005
- Oak Industries, Inc. v. CommissionerUnited States Tax Court · 1991
- Rolfs v. Comm'rUnited States Tax Court · 2010
- Zapara v. Comm'rUnited States Tax Court · 2006
- SMALLEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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