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SMITH v. COMMISSIONER

Docket Nos. 9078-76, 9079-76.

37 T.C.M. 1731 (1978)

T.C. Memo. 1978-416

Jordan K. Smith and Mary F. Smith v. Commissioner. Edward Smith and Modine Smith v. Commissioner.

United States Tax Court.

Filed October 16, 1978.

Attorney(s) appearing for the Case

Paul E. Anderson, 235 Montgomery St., San Francisco, Cal., for the petitioners. Robert E. Casey, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Docket No.  Year    Deficiency

   9078-76    1972    $10,285.00
   9079-76    1972      9,029.00

The issues are whether certain property was a partnership asset and, if so, whether the individual partners' reinvestment in property similar to the involuntarily converted partnership asset...

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