Legal Opinion

Ford v. Commissioner

United States Tax Court

Decided November 12, 1952No. Docket Nos. 9391, 9392, 9393PublishedCited by 2 opinions

Petitioners Clarence B. Ford, Wade E. Moore, and Vern Forcum each originally had a 25 per cent interest in the Forcum-James Construction Company, a partnership, prior to 1940. In 1940 and 1941, each petitioner, with the consent of the other partners, transferred portions of his 25 per cent interest to members of his respective family.

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Petitioners Clarence B. Ford, Wade E. Moore, and Vern Forcum each originally had a 25 per cent interest in the Forcum-James Construction Company, a partnership, prior to 1940. In 1940 and 1941, each petitioner, with the consent of the other partners, transferred portions of his 25 per cent interest to members of his respective family. After such transfers a partnership agreement was entered into admitting to the partnership of Forcum-James Construction Company the parties to whom such transfers had been made. Held, these partnership agreements were entered into by the parties with a bona fide…

1Opinion of the Court

OPINION.

Black, Judge:

Certain minor issues raised by the pleadings have been settled by stipulation. The only issue which remains pertains to the validity of the partnership described in our Findings of Fact. The respondent determined that each petitioner and E. M. Ford owned a 25 per cent interest in tbe partnership Forcum-James during 1942 and 1943. It. M. Ford is not a petitioner before us. Petitioners allege that the partnership was a bona fide legal partnership and was composed of the partners named in our Findings of Fact and with percentage interests named therein.

We have given the…

2Cases cited4 opinions

  1. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  2. Commissioner v. TowerSupreme Court of the United States · 1946
  3. Stern v. CommissionerUnited States Tax Court · 1950
  4. Moore v. CommissionerUnited States Tax Court · 1946

3Cited by2 opinions

  1. Whayne v. GlennDistrict Court, W.D. Kentucky · 1953
  2. Ford v. CommissionerUnited States Tax Court · 1952

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