Quick Trust v. Commissioner
United States Tax Court
Decedent owned a one-half interest in a partnership providing architectural and engineering services. During the period herein relevant, the bulk of the partnership's assets consisted of zero basis accounts receivable for services previously rendered and the partnership had ceased all business activity other than the collection of those accounts. When decedent died, his partnership interest went first to his estate and was later transferred to petitioner.
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Decedent owned a one-half interest in a partnership providing architectural and engineering services. During the period herein relevant, the bulk of the partnership's assets consisted of zero basis accounts receivable for services previously rendered and the partnership had ceased all business activity other than the collection of those accounts. When decedent died, his partnership interest went first to his estate and was later transferred to petitioner. Held: That the right to receive the proceeds of the collection of the accounts receivable was one of the rights included in the partnership…
1Opinion of the Court
OPINION
When Quick died he was an equal partner in a partnership which had been in the business of providing architectural and engineering-services. In 1957, the partnership had ceased all business activity except the collection of outstanding accounts receivable. These receivables, and some cash, were tbe only assets of tbe partnership. Since partnership income was reported on tbe cash basis, tbe receivables bad a zero basis.2
Upon Quick’s death in 1960, tbe estate became a partner with Maguólo and remained a partner until 1965 when it was succeeded as a partner by petitioner herein.3 Tbe…
2Cases cited16 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Foxman v. CommissionerUnited States Tax Court · 1964
- Davenport v. CommissionerUnited States Tax Court · 1967
- Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. HaserotCourt of Appeals for the Sixth Circuit · 1968
- Haserot v. CommissionerUnited States Tax Court · 1966
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3Cited by50 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- University Country Club, Inc. v. CommissionerUnited States Tax Court · 1975
- Rutland v. CommissionerUnited States Tax Court · 1987
- Thoburn v. CommissionerUnited States Tax Court · 1990
- CC & F Western Operations Ltd. Partnership v. CommissionerCourt of Appeals for the First Circuit · 2001
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