Greenspon v. Commissioner
United States Tax Court
1. Individual petitioners received in liquidation upon the dissolution of a corporation in which they were equal stockholders a quantity of industrial pipe that had been the stock in trade, or inventory, of the corporation. They formed a partnership to dispose of the pipe, adding nothing to the quantity they received. Held, the operation of the partnership for the sale of the pipe was a business, and the pipe was held for sale to customers in the regular course of business.
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1. Individual petitioners received in liquidation upon the dissolution of a corporation in which they were equal stockholders a quantity of industrial pipe that had been the stock in trade, or inventory, of the corporation. They formed a partnership to dispose of the pipe, adding nothing to the quantity they received. Held, the operation of the partnership for the sale of the pipe was a business, and the pipe was held for sale to customers in the regular course of business. Profits from the sale of the pipe are the ordinary income of the business and not capital gains from the sale of assets.…
1Opinion of the Court
Louis Greenspon, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Greenspon v. Commissioner
Docket Nos. 39403, 39404, 39405, 39406
United States Tax Court
23 T.C. 138; 1954 U.S. Tax Ct. LEXIS 61;
October 28, 1954, Filed
Decisions will be entered under Rule 50.
1. Individual petitioners received in liquidation upon the dissolution of a corporation in which they were equal stockholders a quantity of industrial pipe that had been the stock in trade, or inventory, of the corporation. They formed a partnership to dispose of the pipe, adding nothing to the quantity they received.…
2Cases cited12 opinions
- Rogers v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
- Thrift v. CommissionerUnited States Tax Court · 1950
- Farley v. CommissionerUnited States Tax Court · 1946
- Greenspon v. CommissionerUnited States Tax Court · 1954
- Ehrman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
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