Legal Opinion

Gunn v. Commissioner

United States Tax Court

Decided October 26, 1967No. Docket No. 5283-64Published

In 1945, the Pine Street apartment building and realty was acquired by petitioner and his wife, Ann, and Jack and Annie Chow. The Gunns and Chows each owned a one-half interest. Ann Gunn was granted a final divorce from petitioner in 1961. The divorce judgment decreed that all the property of the Gunns was community property, and awarded to Fred and Ann, each, an undivided 25-percent interest in the Pine Street property out of their 50-percent interest.

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In 1945, the Pine Street apartment building and realty was acquired by petitioner and his wife, Ann, and Jack and Annie Chow. The Gunns and Chows each owned a one-half interest. Ann Gunn was granted a final divorce from petitioner in 1961. The divorce judgment decreed that all the property of the Gunns was community property, and awarded to Fred and Ann, each, an undivided 25-percent interest in the Pine Street property out of their 50-percent interest. The 50-percent interest of the Chows was recorded in the name of Annie Chow. The Pine Street property was operated as a business through a…

1Opinion of the Court

Fred Wong Gunn, Petitioner v. Commissioner of Internal Revenue, Respondent

Gunn v. Commissioner

Docket No. 5283-64

United States Tax Court

49 T.C. 38; 1967 U.S. Tax Ct. LEXIS 25;

October 26, 1967, Filed

Decision will be entered under Rule 50.

In 1945, the Pine Street apartment building and realty was acquired by petitioner and his wife, Ann, and Jack and Annie Chow. The Gunns and Chows each owned a one-half interest. Ann Gunn was granted a final divorce from petitioner in 1961. The divorce judgment decreed that all the property of the Gunns was community property, and awarded to Fred and Ann, each,…

2Cases cited20 opinions

  1. Lykes v. United StatesSupreme Court of the United States · 1952
  2. Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  3. Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  4. JONES'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
  5. Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944

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