Logan v. Commissioner
United States Tax Court
Petitioner sold his interest in a two-man partnership to his partner and received cash for his share of unbilled work in progress and cash plus an assumption of his share of the partnership liabilities for his partnership interest.
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Petitioner sold his interest in a two-man partnership to his partner and received cash for his share of unbilled work in progress and cash plus an assumption of his share of the partnership liabilities for his partnership interest. Held, the cash representing petitioner's share of work in progress was payment attributable to "unrealized receivables" and taxable as ordinary income under sec. 751(c), I.R.C. 1954. Held, further, petitioner's basis in his partnership interest determined.
1Opinion of the Court
Tannfnwald, Judge:
Respondent determined a deficiency of $2,146.19 in petitioners’ income tax for the taxable year 1961. The only issue is the proper treatment of money received in 1961 from the sale in 1960 of a partnership interest owned by petitioner Frank A. Logan.
FINDINGS OF FACT
Some of the facts are stipulated and are found accordingly.
Petitioners are husband and wife and were legal residents of Anchorage, Ky., at the time of the filing of the petition herein. They filed a joint Federal income tax return for the taxable year 1961 with the district director of internal revenue,…
2Cases cited14 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
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- Stilwell v. CommissionerUnited States Tax Court · 1966
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3Cited by9 opinions
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