Legal Opinion
Karl R. Martin and Kathleen Martin v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 29, 1967No. 17134PublishedCited by 34 opinions
1Per curiam
This is an appeal from a decision of the Tax Court. That decision, reported in 44 T.C. 731 (1965), sets forth the relevant facts in detail and there is no need to repeat them here. Suffice it to say that the main issue before the Tax Court was whether an agreement entitled “Lease with Option to Purchase,” which was entered into by the taxpayer 1 and his associates with the State of Tennessee, was in substance a lease with an option to purchase (the option was later exercised) or whether the agreement constituted an installment sale from its inception. If the former, taxpayer realized…
2Cases cited5 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Martin v. CommissionerUnited States Tax Court · 1965
- J. Strickland & Company v. United StatesCourt of Appeals for the Sixth Circuit · 1965
- Estate of Betty Berry, Deceased, Louis Berry, Louis Berry, Surviving Spouse v. Commissioner of Internal Revenue, Lcg Trust No. 2, A. R. Glancy, Jr., Successor Trustee, Successor Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
3Cited by34 opinions
- Baird v. CommissionerUnited States Tax Court · 1977
- Pacific Coast Music Jobbers, Inc. v. CommissionerUnited States Tax Court · 1971
- Northwest Acceptance Corp. v. CommissionerUnited States Tax Court · 1972
- Pacific Coast Music Jobbers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
- Smith v. CommissionerUnited States Tax Court · 1968
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