ESTATE OF QUIRK v. COMMISSIONER

Docket Nos. 28148-82, 28149-82, 28681-82, 28682-82, 28683-82, 28710-82.

55 T.C.M. 1188 (1988)

T.C. Memo. 1988-286

Estate of Thomas P. Quirk, Deceased, Gregory J. Quirk and Norman D. Rollins, Co-administrators, and Mary C. Quirk, et al. v. Commissioner.

United States Tax Court.

Filed June 29, 1988.


Attorney(s) appearing for the Case

Harvey S. Sander and Jerome R. Rosenberg, 50 Park Ave., New York, N.Y., for the petitioners in docket Nos. 28148-82 and 28149-82. Eugene Chester and James H. Kenworthy, for the petitioners in docket Nos. 28681-82, 28682-82, 28683-82 and 28710-82. Donna I. Epstein, Kevin C. Reilly and Paulette Segal, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

These are consolidated cases for the redetermination of deficiencies in income taxes of the petitioners2 arising out of the withdrawal of a partner from an engineering partnership.3 The issues for decision involve the amount and character of distributions made to a withdrawing partner by a partnership in 1974 and 1975, in liquidation of his partnership...

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