Quick Trust v. Commissioner

54 T.C. 1336, 1970 U.S. Tax Ct. LEXIS 109
CourtUnited States Tax Court
DecidedJune 22, 1970
DocketDocket Nos. 3357-68, 4255-68
StatusPublished
Cited by58 cases

This text of 54 T.C. 1336 (Quick Trust 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
Quick Trust v. Commissioner, 54 T.C. 1336, 1970 U.S. Tax Ct. LEXIS 109 (tax 1970).

Opinion

OPINION

When Quick died he was an equal partner in a partnership which had been in the business of providing architectural and engineering-services. In 1957, the partnership had ceased all business activity except the collection of outstanding accounts receivable. These receivables, and some cash, were tbe only assets of tbe partnership. Since partnership income was reported on tbe cash basis, tbe receivables bad a zero basis.2

Upon Quick’s death in 1960, tbe estate became a partner with Maguólo and remained a partner until 1965 when it was succeeded as a partner by petitioner herein.3 Tbe outstanding accounts receivable were substantial in amount at that time. In its 1960 return, the partnership elected under section 154 4 to make tbe adjustment in tbe basis of tbe partnership property provided for in section 743(b)5 and to allocate that adjustment in accordance with section 755.6 On the facts of tbi.q case, the net result of this adjustment was to increase the basis of the accounts receivable to the partnership from zero to an amount slightly less than one-half of their face value. If such treatment was correct, it substantially reduced the amount of the taxable income to the partnership from the collection of the accounts receivable under section 143 (b) and the estate and the petitioner herein were entitled to the benefit of that reduction.

The issue before us is whether the foregoing adjustment to basis was correctly made. Its resolution depends upon the determination of the basis to the estate of its interest in the partnership, since section 143(b) (1) allows only an “increase [in] the adjusted basis of the partnership property by the excess of the basis to the transferee partner of his interest in the partnership over his proportionate share of the adjusted basis of the partnership property.” (Emphasis added.) This in turn depends upon whether, to the extent that “the basis to the transferee partner” reflects an interest in underlying accounts receivable arising out of personal services of the deceased partner, such interest constitutes income in respect of a decedent under section 691(a)(1) and (3).7 In such event, section 1014(c) comes into play and prohibits equating the basis of Quick’s partnership interest with the fair market value of that interest at the time of his death under section 1014(a).8

Petitioner argues that the partnership provisions of the Internal Eevenue Code of 1954 adopted the entity theory of partnership, that the plain meaning of those provisions, insofar as they relate to the question of basis, requires the conclusion that the inherited partnership interest is separate and distinct from the underlying assets of the partnership, and that, therefore, section 691, and consequently section 1014(c), has no application herein.

Eespondent counters with the assertion that the basis of a partnership interest is determined under section 7429 by reference to other sections of the Code. He claims that, by virtue of section 1014(c), section 1014(a) does not apply to property which is classified as a right to receive income in respect of a decedent under section 691 and that the interest of the estate and of petitioner in the proceeds of the accounts receivable of the partnership falls within this classification. He emphasizes that, since the accounts receivable represent money earned by the performance of personal services, the collections thereon would have been taxable to the decedent, if the partnership had been on the accrual basis, or to the estate and to petitioner if the decedent had been a cash basis sole proprietor. Similarly, he points out that if the business had been conducted by a corporation, the collections on the accounts receivable would have been fully taxable, regardless of Quick’s death. Eespondent concludes that no different result should occur simply because a cash basis partnership is interposed.

The share of a general partner’s successor in interest upon his death in the collections by a partnership on accounts receivable arising out of the rendition of personal services constituted income in respect of a decedent under the 1939 Code. United States v. Ellis, 264 F. 2d 325 (C.A. 2, 1959); Riegelman's Estate v. Commissioner, 253 F. 2d 315 (C.A. 2, 1958), affirming 27 T.C. 833 (1957). Petitioner ignores these decisions, apparently on the ground that the enactment of comprehensive provisions dealing with the taxation of partnerships in the 1954 Code and what it asserts is “the plain meaning” of those provisions render such decisions inapplicable in the instant case. We disagree.

The partnership provisions of the 1954- Code are comprehensive in the sense that they are detailed. But this does not mean that they are exclusive, especially where those provisions themselves recognize the interplay with other provisions of the Code. Section 742 specifies: “The basis of an interest in a partnership acquired other than by contribution shall be determined under part II of subchapter O (sec. 1011 and following).” With the exception of section 722, which deals with the basis of a contributing partner’s interest and which has no applicability herein, this is the only section directed toward the question of the initial determination of the basis of a partnership interest. From the specification of section 742, one is thus led directly to section 1014 and by subsection (c) thereof directly to section 691. Since, insofar as this case is concerned, section 691 incorporates the provisions and legal underpinning of its predecessor (see. 126 of the 1939 Code) ,10 we are directed back to a recognition, under the 1954 Code, of the decisional effect of United States v. Ellis, supra, and Riegelman’s Estate v. Commissioner, supra.

Thus, to the extent that a “plain meaning” can be distilled from the partnership provisions of the 1954 Code, we think that it is contrary to petitioner’s position.11 In point of fact, however, we hesitate to rest our decision in an area such as is involved herein exclusively on such linguistic clarity and purity. See David A. Foxman, 41 T.C. 535, 551 fn. 9 (1964), affd. 352 F. 2d 466 (C.A. 3, 1965). However, an examination of the legislative purpose reinforces our reading of the statute. Section 751, dealing with unrealized receivables and inventory items, is included in subpart D of subchapter K, and is labeled “Provisions Common to Other Subparts.” Both the House and Senate committee reports specifically state that income rights relating to unrealized receivables or fees are regarded “as severable from the partnership interest and as subject to the same tax consequences which would be accorded an individual entrepreneur.” See H. Rept. No. 1337, 83d Cong., 2d Sess., p. 71 (1954); S. Rept. No. 1622, 83d Cong., 2d Sess., p. 99 (1954). And the Senate committee report adds the following significant language.

The Souse Hll provides that a decedent partner’s shave of unrealised receivables ave [sic] to be treated as income in respect of a decedent. 'Such rights to income are to be taxed to the estate or heirs when collected, with an appropriate adjustment for estate taxes.

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Cite This Page — Counsel Stack

Bluebook (online)
54 T.C. 1336, 1970 U.S. Tax Ct. LEXIS 109, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quick-trust-v-commissioner-tax-1970.