Bryant v. Commissioner
United States Tax Court
B (petitioners) negotiated with A for the purchase of a farm. A wanted $ 1,175,500 for the farm. B proposed that the sales contract be drafted so that A would receive $ 925,500 and the remaining $ 250,000 would be simultaneously paid by a third party, provided by B, who would acquire a right to receive $ 250,000 of the farm income to be earned in the future.
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B (petitioners) negotiated with A for the purchase of a farm. A wanted $ 1,175,500 for the farm. B proposed that the sales contract be drafted so that A would receive $ 925,500 and the remaining $ 250,000 would be simultaneously paid by a third party, provided by B, who would acquire a right to receive $ 250,000 of the farm income to be earned in the future. A, whose only interest was to obtain $ 1,175,500 for his farm, agreed to the manner in which B proposed to handle the payments. On March 2, 1963, A and B executed a sales contract which provided, inter alia, that A would retain a $…
1Opinion of the Court
Dawson, Judge:
Respondent determined the following deficiencies in the income taxes of petitioners:
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Some issues raised by the pleadings have been settled by the parties and will be given effect in the Rule 50 computations. Two issues are presented for decision:(1) Whether the amount of $37,399.15 paid in 1963 to the Lubbock National Bank, as trustee, pursuant to production payment provisions in a warranty deed and conveyance, constituted part of the purchase price paid by petitioners for the Coyanosa Farms and must be included in their taxable income for such year.(2) Whether the…
2Cases cited31 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Burnet v. HarmelSupreme Court of the United States · 1932
- Palmer v. BenderSupreme Court of the United States · 1932
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
26 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Olin Bryant and Vanell Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Schultz v. CommissionerUnited States Tax Court · 1968
- Hensel Phelps Constr. Co. v. CommissionerUnited States Tax Court · 1980
26 more not listed; retrieve them via the Exa API.