Pope & Talbot, Inc. v. Commissioner of Internal Revenue

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January 6, 1999

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2611 Pulp Mills
322130 Paperboard Mills
federal taxation
fair market value (FMV)
Pope & Talbot, Inc. v. Commissioner of Internal Revenue
162 F.3d 1236,1999 U.S. App. LEXIS 65
US
Federal Court
9th Circuit
United States Court of Appeals
Noonan, Thompson, Trott

Summary

At issue is the fair market value of the property the plaintiff distribtued to a limited partnership.

See Also

Capital Gains Tax Determined on Value of Property Before Distribution to Transitional Limited Partnership

Legal and Court Case Update
May 1999

Pope & Talbot Inc. distributed certain real property to Pope Resources, a newly formed Delaware limited partnership.

Aggregate Value of Publicly Traded Partnership Units Is Not Equal to the Value of the Underlying Assets

Legal and Court Case Update
January 6, 1999

The 9th Circuit affirmed the Tax Court's decision to calculate the tax due under IRC sec. 311 based on the fair market value of property the corporation transferred to a limited partnership.