Paley v. Commissioner
United States Tax Court
Sec. 117 (j) (2), I. R. C., 1939 -- Partnership Gain and Individual Loss. -- Partnership long-term gains from non-capital assets were long-term capital gains under section 117 (j) in computing the distributable shares of the partnership income, and a partner's share of such gains does not offset his long-term losses from individually owned non-capital assets under section 117 (j) (2).
1Opinion of the Court
Jacob (Jay) Paley and Lillian Paley, Petitioners, v. Commissioner of Internal Revenue, Respondent
Paley v. Commissioner
Docket No. 40898
United States Tax Court
22 T.C. 1236; 1954 U.S. Tax Ct. LEXIS 102;
September 21, 1954, Filed September 21, 1954, Filed
Decision will be entered under Rule 50.
Sec. 117 (j) (2), I. R. C., 1939 -- Partnership Gain and Individual Loss. -- Partnership long-term gains from non-capital assets were long-term capital gains under section 117 (j) in computing the distributable shares of the partnership income, and a partner's share of such gains does not offset his long-term…
2Cases cited2 opinions
- Ammann v. CommissionerUnited States Tax Court · 1954
- Paley v. CommissionerUnited States Tax Court · 1954