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St. John v. United States

The taxpayer sold interests in a general partnership formed to construct a nursing home and received a subordinated profits interest in the partnership.

The Internal Revenue Service contended that the taxpayer must report the profits interest as ordinary income in the amount of the fair market value of such interest as of the date of the formation of the partnership rather then when the restrictions on the taxpayer’s right to receive profits lapsed.  No. 82-1134 (D. Ill. 1983).

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