Court rules on taxpayers’ disposal of partnership interests

The U.S. Tax Court has upheld the IRS determination that two brothers’ losses on the disposal of partnership interests weren’t ordinary abandonment losses, as they claimed on their returns, but rather were capital losses. The court also rejected the brothers’ argument that they received proceeds from the sale, which were used to acquire an intangible asset they were entitled to amortize. This argument was “contrary to the unambiguous terms” of the partnership agreement.