Jacobson v. Commissioner
United States Tax Court
Ps owned 100 percent of JWC, a partnership. JWC and M formed a partnership, V, wherein JWC and M had respective ownership interests of 25 percent and 75 percent. JWC transferred property to V and M transferred cash equal to 75 percent of the agreed value of the property to V. The cash was immediately transferred by V to or for the benefit of JWC.
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Ps owned 100 percent of JWC, a partnership. JWC and M formed a partnership, V, wherein JWC and M had respective ownership interests of 25 percent and 75 percent. JWC transferred property to V and M transferred cash equal to 75 percent of the agreed value of the property to V. The cash was immediately transferred by V to or for the benefit of JWC. Ps reported the transaction as a contribution of property by JWC to V under sec. 721, I.R.C., followed by a distribution from V to JWC under sec. 731, I.R.C.Held: The transaction was in substance a sale by JWC of a 75-percent interest in the property…
1Opinion of the Court
PARR, Judge:
Respondent determined that petitioners in these consolidated cases were Hable for the foUowing deficiencies in their joint Federal income tax:
Calendar
Petitioners Docket No. year Deficiency
Richard O. Jacobson and Cheryl H. Jacobson 5866-87 1982 $202,604
Lawrence E. Larson and 6286-87 1982 78,083
Donna C. Larson 1983 1,304
With the Court’s permission, respondent amended his answer in docket No. 5866-87 to include a concession and to correct certain computational errors contained in the notice of deficiency. The effect of respondent’s amendment to his answer was to increase the amount…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Otey v. CommissionerUnited States Tax Court · 1978
- John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
- Jupiter Corp. v. United StatesUnited States Court of Claims · 1983
3 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Richard O. Jacobson, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
- Great Plains Gasification Assocs. v. Comm'rUnited States Tax Court · 2006
- Jacobson v. CommissionerUnited States Tax Court · 1991
- NORMAN v. COMMISSIONERUnited States Tax Court · 2006