Legal Opinion

Jacobson v. Commissioner

United States Tax Court

Decided April 2, 1991No. Docket Nos. 5866-87, 6286-87Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Otey v. CommissionerUnited States Tax Court · 1978
  3. John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
  4. Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
  5. Jupiter Corp. v. United StatesUnited States Court of Claims · 1983

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