McDougal v. Commissioner
United States Tax Court
As compensation for services rendered, the McDougals gave McClanahan a 50-percent interest in the capital and profits of a joint venture to which the McDougals contributed appreciated property. Held, that the McDougals recognized gain to the extent that the value of a half interest in the contributed property exceeded the McDougal's adjusted basis in the aforesaid half interest.
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As compensation for services rendered, the McDougals gave McClanahan a 50-percent interest in the capital and profits of a joint venture to which the McDougals contributed appreciated property. Held, that the McDougals recognized gain to the extent that the value of a half interest in the contributed property exceeded the McDougal's adjusted basis in the aforesaid half interest. Held, further, that in determining the joint venture's basis in the contributed property, it is to be deemed that the McDougals transferred a half interest in the said property to McClanahan and thereafter, in concert…
1Opinion of the Court
Fat, Judge:
The respondent has determined the following deficiencies in, and additions to, the income tax of the jietitioners:
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The petitioners have in turn claimed income tax refunds for the aforesaid years.
Mutual concessions having been made, the following issues remain to be decided:(1) Did the McDougals’ transfer of a one-half interest in the racehorse, Iron Card, to Gilbert McClanahan constitute a gift, or alternatively, did the aforesaid transfer constitute a contribution to an oral partnership or joint venture previously or contemporaneously formed by the McDougals and…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- United States v. DavisSupreme Court of the United States · 1962
- Luna v. CommissionerUnited States Tax Court · 1964
- Hoffman v. CommissionerUnited States Tax Court · 1943
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Helmer v. CommissionerUnited States Tax Court · 1975
- Boca Investerings Partnership v. United StatesDistrict Court, District of Columbia · 2001
- M. H. S. Co. v. CommissionerUnited States Tax Court · 1976
- Long v. Comm'rUnited States Tax Court · 2013
- McDougal v. CommissionerUnited States Tax Court · 1974
2 more not listed; retrieve them via the Exa API.