Legal Opinion

Jackson Inv. Co. v. Commissioner

United States Tax Court

Decided February 26, 1964No. Docket Nos. 94203, 94204Published

Payments were made by a partnership to a retiring partner in liquidation of her partnership interest, and an amount was paid for goodwill, even though the partnership agreement was silent regarding goodwill. Held, the payment for goodwill was within the purview of sec. 736(a)(2), I.R.C. 1954, and was deductible by the partnership.

1Opinion of the Court

Jackson Investment Company, Petitioner, v. Commissioner of Internal Revenue, Respondent; West Shore Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Jackson Inv. Co. v. Commissioner

Docket Nos. 94203, 94204

United States Tax Court

41 T.C. 675; 1964 U.S. Tax Ct. LEXIS 145;

February 26, 1964, Filed

Decisions will be entered under Rule 50.

Payments were made by a partnership to a retiring partner in liquidation of her partnership interest, and an amount was paid for goodwill, even though the partnership agreement was silent regarding goodwill. Held, the payment for goodwill was…

Also in this document: Concurrence; Dissent.

2Cases cited5 opinions

  1. Miller v. RobertsonSupreme Court of the United States · 1924
  2. Foxman v. CommissionerUnited States Tax Court · 1964
  3. Smith v. CommissionerUnited States Tax Court · 1962
  4. V. Zay Smith, and Ida Smith v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1963
  5. Jackson Inv. Co. v. CommissionerUnited States Tax Court · 1964

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