26 U.S.C. § 722
Basis of contributing partner’s interest
The basis of an interest in a partnership acquired by a contribution of property, including money, to the partnership shall be the amount of such money and the adjusted basis of such property to the contributing partner at the time of the contribution increased by the amount (if any) of gain recognized under section 721(b) to the contributing partner at such time.
Notes of Decisions
Cited in 47
cases, 1948–2015 · leading case: Bemont Investments, L.L.C. Ex Rel. Tax Matters Partner v. United States, 679 F.3d 339 (5th Cir. 2012).
Bemont Investments, L.L.C. Ex Rel. Tax Matters Partner v. United States, 679 F.3d 339 (5th Cir. 2012). “26 U.S.C. § 722 . When a partnership assumes a partner's liability, the partner's basis decreases.”
United States v. Woods, 134 S. Ct. 557 (2013). “See 26 U.S.C. § 722 . Collectively, Woods and McCombs contributed roughly $3.”
Stobie Creek Investments LLC v. United States, 608 F.3d 1366 (Fed. Cir. 2010). “See 26 U.S.C. §§ 722 , 733, 752, 754; see also IRS Notice No.”
Marriott Int'l Resorts, L.P. v. United States, 586 F.3d 962 (Fed. Cir. 2009). “With him on the briefs were Robert L. Willmore and Alex E. Sadler, Crowell & Moring LLP, Washington, DC.”
Superior Trading, LLC v. Comm'r, 728 F.3d 676 (7th Cir. 2013). “26 U.S.C. § 722 . If he paid $100 for an asset once worth $1000, he could not claim a loss of $900— the full built-in loss—but only of $100; the other $800 of losses would be wasted from a tax-avoidance standpoint.”
Urban Hotel Dev. Co. v. President Dev. Grp., L.C., 535 F.3d 874 (8th Cir. 2008). “For partnerships, a tax basis results from contributing property, including money, see 26 U.S.C. §§ 722 , 723, or assuming the liabilities of a partnership, see 26 U.”
Petaluma FX Partners, LLC v. Comm'r of IRS, 792 F.3d 72 (D.C. Cir. 2015). “See 26 U.S.C. § 722 . Each of the Vander-beeks, upon contributing his paired options to Petaluma, increased his outside basis to account for the value of his contributed long option.”
Dowd-Feder, Inc. v. Comm'r of Internal Revenue, 173 F.2d 673 (6th Cir. 1949). “The Tax Court held that there is no deficiency in the excess profits tax for that *674 year; but that where the amount of excess profits credits, computed by using average base period net income reconstructed under section 722 of the Internal Revenue Code, 26 U.S.C.A. § 722 , is…”
Arkansas Motor Coaches, Ltd., Inc. v. Comm'r of Internal Revenue, 198 F.2d 189 (8th Cir. 1952). “This is a petition to review a decision of the Tax Court of the United States dismissing for lack of jurisdiction petitioner’s petition for redetermination of excess profit taxes for the year 1942 under the provisions of Section 722 of the Internal Revenue Code, 26 U.S.C.A. §…”
United States v. Koppers Co., 348 U.S. 254 (1955). “601 -602, 26 U. S. C. § 722 (a) (d). The above provisions of § 722 (d) apply to taxable years beginning after December 31, 1939.”
Reo Motors, Inc. v. Comm'r of Internal Revenue, 219 F.2d 610 (6th Cir. 1955). “been used there would have been no deficiency in petitioner’s excess profits tax for 1942; that the Commissioner had admitted this error in connection with another proceeding involving petitioner’s excess profits tax liability for 1943; that in 1949 the petitioner had sought…”
Cent. Paper Co. v. Comm'r of Internal Revenue, 199 F.2d 902 (6th Cir. 1952). “, a Michigan 'Corporation, filed claims for refund, relating to' the application of § 722 of the Internal Revenue Code, 26 U.S. C.A. § 722, with respect to excess profits *903 taxes for the fiscal years ending June 30, 1943, 1944 and 1945.”
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