Legal Opinion
Wilford E. Thatcher v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided March 17, 1976No. 74-2245PublishedCited by 6 opinions
1Opinion of the Court
ALFRED T. GOODWIN, Circuit Judge:
Two individual taxpayers and a corporation seek reversal of a Tax Court decision 1 holding taxable as a gain under 26 U.S.C. § 357(c) (1970) 2 the excess of partnership liabilities assumed by the corporation over the partners’ basis in the assets they transferred to the corporation in a § 351 exchange. 3
From 1956 to 1963, Wilford Thatcher and Karl Teeples engaged in business as partners. The enterprise acquired diversified assets and liabilities. The partners filed tax returns under the cash receipts and disbursements method of accounting. In 1963, the…
2Cases cited5 opinions
- Klamath Medical Service Bureau v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Raich v. CommissionerUnited States Tax Court · 1966
- John P. And Alice Bongiovanni v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1972
- N. F. Testor v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Thatcher v. CommissionerUnited States Tax Court · 1973
3Cited by6 opinions
- Focht v. CommissionerUnited States Tax Court · 1977
- Sol Lessinger and Edith Lessinger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1989
- Christopher v. CommissionerUnited States Tax Court · 1984
- Focht v. CommissionerUnited States Tax Court · 1977
- Focht v. CommissionerUnited States Tax Court · 1977
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