Pope & Talbot, Inc. v. Commissioner of Internal Revenue
United States Court of Appeals for the Ninth Circuit
162 F.3d 1236 (1999)

- Written by Kelly Simon, JD
Facts
In 1985, the board and shareholders of Pope & Talbot, Inc. (plaintiff) approved a plan of distribution (the plan) to transfer timberlands, timber, land-development, and resort businesses in the state of Washington (collectively, the Washington properties) to a limited partnership, Pope Resources (the partnership). The plan required that when the Washington properties transferred to the partnership, the partnership would issue limited partnership interests to one of the partners. That partner would then issue and distribute the limited-partnership units to Pope & Talbot shareholders on a pro rata basis.
Rule of Law
Issue
Holding and Reasoning (Thompson, J.)
What to do next…
Here's why 824,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,400 briefs, keyed to 989 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.