Legal Opinion

La Rue v. Commissioner

United States Tax Court

Decided March 21, 1988No. Docket Nos. 22164-80, 22165-80, 1014-81, 3726-81, 20879-81, 21096-81, 23909-81, 21199-82, 1867-83Published

Ps were general partners in Goodbody, a stock brokerage firm. Due to the failure of record-keeping technology to keep up with trading volume, Goodbody incurred large, anticipated "back office" liabilities to its customers and other stock brokerage firms, precipitating withdrawals of firm capital and violation of New York Stock Exchange rules.

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Ps were general partners in Goodbody, a stock brokerage firm. Due to the failure of record-keeping technology to keep up with trading volume, Goodbody incurred large, anticipated "back office" liabilities to its customers and other stock brokerage firms, precipitating withdrawals of firm capital and violation of New York Stock Exchange rules. In order to prevent the financial collapse of Goodbody, M Corp. agreed to assume Goodbody's business, all its assets and liabilities, subject to an obligation by Ps to pay to M any deficit in Goodbody's net worth. Held, liabilities attributable to an…

1Opinion of the Court

Joseph W. La Rue, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

La Rue v. Commissioner

Docket Nos. 22164-80, 22165-80, 1014-81, 3726-81, 20879-81, 21096-81, 23909-81, 21199-82, 1867-83

United States Tax Court

90 T.C. 465; 1988 U.S. Tax Ct. LEXIS 33; 90 T.C. No. 33;

March 21, 1988; As amended March 28, 1988 March 21, 1988, Filed

Decisions will be entered under Rule 155.

Ps were general partners in Goodbody, a stock brokerage firm. Due to the failure of record-keeping technology to keep up with trading volume, Goodbody incurred large, anticipated "back office" liabilities to…

2Cases cited24 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  4. Commissioner v. TuftsSupreme Court of the United States · 1983
  5. United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986

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