Legal Opinion

Paley v. Commissioner

United States Tax Court

Decided September 21, 1954No. Docket No. 40898Published

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

  1. Ammann v. CommissionerUnited States Tax Court · 1954
  2. Paley v. CommissionerUnited States Tax Court · 1954

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