Foxman v. Commissioner

41 T.C. 535, 1964 U.S. Tax Ct. LEXIS 163
CourtUnited States Tax Court
DecidedJanuary 16, 1964
DocketDocket Nos. 93416, 93460, 93472
StatusPublished
Cited by92 cases

This text of 41 T.C. 535 (Foxman v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foxman v. Commissioner, 41 T.C. 535, 1964 U.S. Tax Ct. LEXIS 163 (tax 1964).

Opinion

OPINION

Raum, Judge:

1. Tax consequences of termination of Jacdbowitz’s interest in Abbey; the agreement of May 21, 1957. — On May 21, 1957, Jacobowitz’s status as a partner in Abbey came to an end pursuant to an agreement executed on that day. The first issue before us is whether Jacobowitz thus made a “sale” of his partnership interest to Foxman and Grenell within section 7412 of the 1954 Code, as contended by him, or whether the payments to him required by the agreement are to be regarded as “made in liquidation” of his interest within section 736,3 as contended by Foxman and Grenell. Jacobo-witz treated the transaction as constituting a “sale,” and reported a capital gain thereon in his return for 1957. Foxman and Grenell, on the other hand, treated the payments as having been “made in liquidation”4 of Jacobowitz’s interest under section 736, with the result that a substantial portion thereof reduced their distributive shares of partnership income for the fiscal year ending February 28, 1958.

The Commissioner, in order to protect the revenues, took inconsistent positions. In Jacobowitz’s case, his determination proceeded upon the assumption that there was a section 736 “liquidation,” with the result that payments thereunder were charged to Jaco'bowitz for the partnership fiscal year ending February 28, 1958, thus not only attributing to Jacobowitz additional income for his calendar year 1958 but also treating it as ordinary income rather than capital gain. In the cases of Foxman and Grenell, the Commissioner adopted Jacobowitz’s position that there was a section 741 “sale” on May 21, 1957, to Foxman and Grenell, thus disallowing the deductions in respect thereof from the partnership’s income for its fiscal year ending February 28, 1958; as a consequence, there was a corresponding increase in the distributive partnership income of Foxman and Grenell for that fiscal year which was reflected in the deficiencies determined for the calendar year 1958 in respect of each of them.

As is obvious, the real controversy herein is not between the various petitioners and the Government,5 but rather between Jacobowitz and his two former partners. We hold, in favor of Jacobowitz, that the May 21,1957, transaction was a “sale” under section 741.

The provisions of sections 736 and 741 of the 1954 Code have no counterpart in prior law. They are contained in “Subchapter K” 6 which for the first time, in 1954, undertook to deal comprehensively with the income tax problems of partners and partnerships.

That a partnership interest may be “sold” to one or more members of the partnership within section 741 is not disputed by any of the parties. Indeed, the Income Tax Regulations, section 1.741-1 (b), explicitly state:

Sec. 1.741-1 Recognition and character of gain or loss on sale or exchange.
* * * * » * *
(b) Section 741 shall apply whether the partnership interest is sold to one or more members of the partnership or to one or more persons who are not members of the partnership. * * *

And it is clear that in such circumstances, sections 736 and 761(d), do not apply. See regulations, sec. 1.736-1(a)(1)(i) :

Sec. 1.736-1 Payments to a retiring partner or a deceased partner’s successor in interest.
(a) Payments considered as distributive share or guaranteed payment. (1)(i) Section 736 and this section apply only to payments made to a retiring partner or to a deceased partner’s successor in interest in liquidation of such partner’s entire interest in the partnership. See section 761(d). * * * Section 736 and this section apply only to payments made by the partnership and not to transactions between the partners. Thus, a sale by partner A to partner B of his entire one-fourth interest in partnership ABOD would not come within the scope of section 736. [Italics supplied.]

Did Jacobowitz sell his interest to Foxman and Grenell, or did he merely enter into an arrangement to receive “payments * * * in liquidation of [his] * * * interest” from the partnership ? We think the record establishes that he sold his interest.

At first blush, one may indeed wonder why Congress provided for such drastically different tax consequences, depending upon whether the amounts received by the withdrawing partner are to be classified as the proceeds of a “sale” or as “payments * * * in liquidation” of his interest.7 For, there may be very little, if any, difference in ultimate economic effect between a “sale” of a partnership interest to the remaining- partners and a “liquidation” of that interest. In the case of a sale the remaining partners may well obtain part or all of the needed cash to pay the purchase price from the partnership assets, funds borrowed by the partnership or future earnings of the partnership. See A.L.I., Federal Income Taxation of Partners and Partnerships 176 (1957). Yet the practical difference between such transaction and one in which the withdrawing partner agrees merely to receive payments in liquidation directly from the partnership itself would hardly be a meaningful one in most circumstances.8 Why then the enormous disparity in tax burden, turning upon what for practical purposes is merely the difference between Tweedledum and Tweedledee, and what criteria are we to apply in our effort to discover that difference in a particular case? The answer to the first part of this question is to be found in the legislative history of subchapter K, and it goes far towards supplying the answer to the second part.

In its report on the bill which became the 1954 Code the House Ways and Means Committee stated that the then “existing tax treatment of partners and partnerships is among the most confused in the entire tax field”; that “partners * * * cannot form, operate, or dissolve a partnership with any assurance as to tax consequences”; that the proposed statutory provisions [subchapter K] represented the “first comprehensive statutory treatment of partners and partnerships in the history of the income tax laws”; and that the “principal objectives have been simplicity, flexibility, and equity as between the partners.” H. Rept. No. 1337, 83d Cong., 2d Sess., p. 65. Like thoughts were expressed in virtually identical language by the Senate Finance Committee. S. Rept. No. 1622, 83d Cong., 2d Sess., p. 89.

Although there can be little doubt that the attempt to achieve “simplicity” has resulted in utter failure,9 the new legislation was intended to and in fact did bring into play an element of “flexibility.” Tax law in respect of partners may often involve a delicate mechanism, for a ruling in favor of one partner may automatically produce adverse consequences to the others. Accordingly, one of the underlying philosophic objectives of the 1954 Code was to permit the partners themselves to determine their tax burdens inter sese to a certain extent, and this is what the committee reports meant when they referred to “flexibility.” The theory was that the partners would take their prospective tax liabilities into account in bargaining with one another.10

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Bluebook (online)
41 T.C. 535, 1964 U.S. Tax Ct. LEXIS 163, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foxman-v-commissioner-tax-1964.