Ford v. Comm'r
United States Tax Court
In 1932 petitioners, along with Sara C. Ford, formed a partnership. In 1938 petitioners, as individuals, purchased for cash the one-third interest of Sara C. Ford in the partnership. In the taxable year 1941 the partnership sold certain of its capital assets. In their individual returns petitioners claimed their proportionate share of the loss from such sale on the basis of the original cost of the assets to the partnership.
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In 1932 petitioners, along with Sara C. Ford, formed a partnership. In 1938 petitioners, as individuals, purchased for cash the one-third interest of Sara C. Ford in the partnership. In the taxable year 1941 the partnership sold certain of its capital assets. In their individual returns petitioners claimed their proportionate share of the loss from such sale on the basis of the original cost of the assets to the partnership. In determining the deficiencies, respondent adjusted the cost basis, allowing two-thirds of the original cost plus one-third of the fair market value of the assets as of…
1Opinion of the Court
OPINION.
Leech, Judge:
These consolidated proceedings involve deficiencies in income taxes for the year 1941 in the respective amounts of $1,187.78 and $1,484.78. By amended petitions filed at the hearing, petitioners in Docket No. 3947 claim overpayment of income taxes in the amount of $3,137.93 and in Docket No. 3948, in the amount of $1,901.23. The issues are: (1) Whether the cost basis of partnership assets should be adjusted upon the purchase of the interest of a withdrawing part’ ner; and (2) whether petitioners are entitled to deduct in 1941 a loss with respect to bonds of an Italian…
2Cases cited3 opinions
- Burwell v. CawoodSupreme Court of the United States · 1844
- Thornley v. CommissionerUnited States Tax Court · 1943
- Smith v. CommissionerUnited States Tax Court · 1945
3Cited by40 opinions
- Casey v. CommissionerUnited States Tax Court · 1962
- Mnookin v. CommissionerUnited States Tax Court · 1949
- Lehman v. CommissionerUnited States Tax Court · 1946
- Haley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- United States v. ShapiroCourt of Appeals for the Eighth Circuit · 1949
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