Hensel Phelps Construction Company, and Cross-Appellee v. Commissioner of Internal Revenue, and Cross-Appellant

LOGAN, Circuit Judge.

Hensel Phelps Construction Company appeals a decision of the United States Tax Court affirming the Commissioner’s determination of a deficiency against it for its tax year ending May 31, 1974. The court held that Hensel Phelps received a partnership interest in that year in exchange for services and failed to include the value of that interest in its taxable income. The court established the amount to be included at $239,151. See Hensel Phelps Construction Co., 74 T.C. 939 (1980). Hensel Phelps challenges the decision of the Tax Court, arguing: (1) the court erred in…