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THOMPSON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 10927, 10928.

205 F.2d 73 (1953)

THOMPSON v. COMMISSIONER OF INTERNAL REVENUE. COUSE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Third Circuit.

Decided June 8, 1953.

Attorney(s) appearing for the Case

Israel B. Greene, Newark, N. J. (Bernard Hellring, Newark, N. J., Warren J. Greene, Newark, N. J., on the brief), for appellants.

Cecelia H. Goetz, Washington, D. C. (Charles S. Lyon, Asst Atty. Gen. and Ellis N. Slack, Sp. Assts. to Atty. Gen., on the brief), for appellee.

Before KALODNER, STALEY and HASTIE, Circuit Judges.

KALODNER, Circuit Judge.

These appeals involve certain government contracts, awarded to a corporation which later dissolved and whose principal stockholder paid a capital gains tax on the value of the contracts (estimated profits) in excess of his basis in the assets of the corporation and then contributed his interest to a partnership later formed. The question presented is whether the partnership may use the value of the contracts as thus determined as a basis for...

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