Jacobson v. Commissioner
United States Tax Court
Ps owned 100 percent of JWC, a partnership. JWC and M formed a partnership, V, wherein JWC and M had respective ownership interests of 25 percent and 75 percent. JWC transferred property to V and M transferred cash equal to 75 percent of the agreed value of the property to V. The cash was immediately transferred by V to or for the benefit of JWC.
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Ps owned 100 percent of JWC, a partnership. JWC and M formed a partnership, V, wherein JWC and M had respective ownership interests of 25 percent and 75 percent. JWC transferred property to V and M transferred cash equal to 75 percent of the agreed value of the property to V. The cash was immediately transferred by V to or for the benefit of JWC. Ps reported the transaction as a contribution of property by JWC to V under sec. 721, I.R.C., followed by a distribution from V to JWC under sec. 731, I.R.C.Held: The transaction was in substance a sale by JWC of a 75-percent interest in the property…
1Opinion of the Court
Richard O. Jacobson and Cheryl H. Jacobson, Petitioners v. Commissioner of Internal Revenue, Respondent; Lawrence E. Larson and Donna C. Larson, Petitioners v. Commissioner of Internal Revenue, Respondent
Jacobson v. Commissioner
Docket Nos. 5866-87, 6286-87
United States Tax Court
96 T.C. 577; 1991 U.S. Tax Ct. LEXIS 27; 96 T.C. No. 21;
April 2, 1991, Filed
Decisions will be entered under Rule 155.
Ps owned 100 percent of JWC, a partnership. JWC and M formed a partnership, V, wherein JWC and M had respective ownership interests of 25 percent and 75 percent. JWC transferred property to V and M…
2Cases cited9 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Otey v. CommissionerUnited States Tax Court · 1978
- John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
- Jupiter Corp. v. United StatesUnited States Court of Claims · 1983
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