Cooney v. Commissioner
United States Tax Court
In 1966, petitioners were partners in a law firm with nine members. Effective Dec. 31, 1966, three members withdrew from the firm. They each received a promissory note and were relieved of their proportionate share of the indebtedness of the partnership. During 1967, the continuing partnership paid the notes and the assumed indebtedness.
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In 1966, petitioners were partners in a law firm with nine members. Effective Dec. 31, 1966, three members withdrew from the firm. They each received a promissory note and were relieved of their proportionate share of the indebtedness of the partnership. During 1967, the continuing partnership paid the notes and the assumed indebtedness. Held: The transaction whereby the partners withdrew from the partnership was a liquidation of their interests under sec. 736, I.R.C. 1954, rather than a sale under sec. 741, I.R.C. 1954. The payments made to and on behalf of the withdrawing partners are…
1Opinion of the Court
William J. Cooney, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Cooney v. Commissioner
Docket Nos. 8784-73, 8840-73, 8870-73, 9101-73, 9102-73
United States Tax Court
65 T.C. 101; 1975 U.S. Tax Ct. LEXIS 51;
October 21, 1975, Filed
Decisions will be entered under Rule 155.
In 1966, petitioners were partners in a law firm with nine members. Effective Dec. 31, 1966, three members withdrew from the firm. They each received a promissory note and were relieved of their proportionate share of the indebtedness of the partnership. During 1967, the continuing partnership paid the…
2Cases cited9 opinions
- Foxman v. CommissionerUnited States Tax Court · 1964
- Karan v. CommissionerCourt of Appeals for the Seventh Circuit · 1963
- Smith v. CommissionerUnited States Tax Court · 1962
- V. Zay Smith, and Ida Smith v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
- Swygert Bros. v. Bank of HaralsonCourt of Appeals of Georgia · 1913
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