Coupe v. Comm'r
United States Tax Court
Petitioners contracted to sell their farm (Elk Grove), which included about 2 acres immediately surrounding their residence, to S.P. for $ 2,500 per acre in a series of conveyances. S.P. contracted to pay interest on all deferred payments. Subsequently petitioners and S.P. reformed their contract so that petitioners exchanged parcels of Elk Grove with third parties for (respectively) property of like kind, a deed-of-trust note, a new residence, and cash.
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Petitioners contracted to sell their farm (Elk Grove), which included about 2 acres immediately surrounding their residence, to S.P. for $ 2,500 per acre in a series of conveyances. S.P. contracted to pay interest on all deferred payments. Subsequently petitioners and S.P. reformed their contract so that petitioners exchanged parcels of Elk Grove with third parties for (respectively) property of like kind, a deed-of-trust note, a new residence, and cash. Said third parties included petitioners' attorneys, who purchased the exchange properties in their own names. Simultaneously the third…
1Opinion of the Court
Leslie Q. Coupe and Maybelle Coupe, Petitioners v. Commissioner of Internal Revenue, Respondent
Coupe v. Comm'r
Docket No. 861-65
United States Tax Court
52 T.C. 394; 1969 U.S. Tax Ct. LEXIS 116;
June 11, 1969, Filed
Decision will be entered under Rule 50.
Petitioners contracted to sell their farm (Elk Grove), which included about 2 acres immediately surrounding their residence, to S.P. for $ 2,500 per acre in a series of conveyances. S.P. contracted to pay interest on all deferred payments. Subsequently petitioners and S.P. reformed their contract so that petitioners exchanged parcels of Elk Grove…
Also in this document: Concurrence; Dissent.
2Cases cited26 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Aquilino v. United StatesSupreme Court of the United States · 1960
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. LesterSupreme Court of the United States · 1961
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