Quimbee logo
DMCA.com Protection Status

Jacobson v. Commissioner

96 T.C. 577 (1991)

Case BriefRelatedOptions
From our private database of 28,700+ case briefs...

Jacobson v. Commissioner

United States Tax Court

96 T.C. 577 (1991)

Facts

Richard Jacobson and Lawrence Larson (plaintiffs) were general partners of Jacobson Warehouse Company (JWC), which owned the McDonald properties. JWC attempted to sell the McDonald properties for two years before it formed a partnership with Metropolitan Life Insurance Company (Metropolitan) (the partnership). In 1982 JWC contributed the McDonald properties to the partnership, and Metropolitan contributed $6 million in cash. Because the McDonald properties had a value of approximately $8 million, Metropolitan’s cash contribution equaled 75 percent of JWC’s contribution. Metropolitan’s cash contribution was immediately disbursed to JWC. After these transactions and in accordance with the partnership agreement, Metropolitan owned 75 percent of the partnership, while JWC received cash for 75 percent of the value of the McDonald properties and owned 25 percent of the partnership. Jacobsen and Larson did not include their transfer of the McDonald properties to the partnership on their income-tax return, arguing the transfer was a nontaxable capital contribution under § 721 of the Internal Revenue Code. The Commissioner of Internal Revenue (the Commissioner) (defendant) assessed a deficiency against Jacobson and Larson, arguing 25 percent of the transfer of the McDonald properties was a nontaxable capital contribution in exchange for a 25 percent partnership share, with the remaining 75 percent a taxable sale. Jacobson and Larson petitioned the United States Tax Court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Parr, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 546,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 546,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 28,700 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 546,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 28,700 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership