Richard O. Jacobson, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson v. Commissioner of Internal Revenue

Richard O. Jacobson, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson appeal from the tax court’s 1 decision characterizing the formation of a partnership, the Metropolitan-Jacobson Development Venture (Venture), 2 as a nontaxable capital contribution by JWC to Venture of 25 percent of JWC’s interest in certain property (the McDonald properties) in exchange for a 25 percent partnership interest in Venture and a taxable sale by JWC of 75 percent of the McDonald properties for cash, rather than as a nontaxable capital contribution of the McDonald properties by JWC to Venture under 26…