Sherlock v. Commissioner
United States Tax Court
1. Held, where principal petitioner sold his interest in a partnership prior to the end of the partnership's regular taxable year following which the partnership was dissolved, he is taxable upon his distributive share of the net income of the partnership for its taxable period ending at the date of dissolution. 2. Adjusted basis for petitioner's interest in such partnership is determined. 3. Held, petitioners are liable for additions to tax under sections 294(d)(1)(B) and…
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1. Held, where principal petitioner sold his interest in a partnership prior to the end of the partnership's regular taxable year following which the partnership was dissolved, he is taxable upon his distributive share of the net income of the partnership for its taxable period ending at the date of dissolution. 2. Adjusted basis for petitioner's interest in such partnership is determined. 3. Held, petitioners are liable for additions to tax under sections 294(d)(1)(B) and 294(d)(2) of the 1939 Code.
1Opinion of the Court
Pierce, Judqe:
The respondent determined a deficiency in the petitioners’ income tax for the year 1954, and additions to tax, as follows:
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The issues for decision are:(1) Where the principal petitioner, Chris J. Sherlock, sold his interest in a partnership prior to the end of the partnership’s regular taxable year, is he taxable on his distributive share of the partnership income for the period ending with such sale?(2) What was petitioner’s basis for the interest in the partnership which he sold?(8) Are petitioner and his wife liable for additions to tax under sections 294(d) (1)…
2Cases cited12 opinions
- Bull v. United StatesSupreme Court of the United States · 1935
- Helvering v. EubankSupreme Court of the United States · 1941
- Commissioner v. AckerSupreme Court of the United States · 1959
- James M. Tunnell, Jr., and Mildred S. Tunnell v. United StatesCourt of Appeals for the Third Circuit · 1958
- Karsch v. CommissionerUnited States Tax Court · 1947
7 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Sherlock v. CommissionerCourt of Appeals for the Fifth Circuit · 1961
- Myers v. CommissionerUnited States Tax Court · 1962
- Chris J. Sherlock v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
- Leblanc v. United StatesUnited States Court of Federal Claims · 2009
- Lessmann v. CommissionerUnited States Tax Court · 1962
5 more not listed; retrieve them via the Exa API.