Rudd v. Commissioner
United States Tax Court
Petitioner was a partner in a public accounting firm that was well established and well known in the Muskegon, Mich., area. The firm was dissolved in 1971. Upon dissolution of the firm, the rights to the use of its name were distributed to petitioner and four other partners, who then abandoned the use of the name. In 1971, petitioner and two other partners of the dissolved firm became partners in a national public accounting firm.
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Petitioner was a partner in a public accounting firm that was well established and well known in the Muskegon, Mich., area. The firm was dissolved in 1971. Upon dissolution of the firm, the rights to the use of its name were distributed to petitioner and four other partners, who then abandoned the use of the name. In 1971, petitioner and two other partners of the dissolved firm became partners in a national public accounting firm. Held: 1. The partnership's name was a clearly identifiable and severable intangible asset for which petitioner is entitled to a loss deduction under sec. 165,…
1Opinion of the Court
Chabot, Judge:
Respondent determined a deficiency in Federal individual income tax against petitioner for 1971 in the amount of $17,098. The issue for decision is whether petitioner is entitled to a loss deduction under section 1651 in 1971 for abandonment of a partnership name and, if so, in what amount.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulation and the stipulated exhibits are incorporated herein by this reference.
When the petition in this case was filed, petitioner resided in Fruitport, Mich.
Maihofer, Moore & DeLong (hereinafter sometimes referred to as the…
2Cases cited12 opinions
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- Horton v. CommissionerUnited States Tax Court · 1949
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