Arnwine v. Commissioner
United States Tax Court
In March 1973, petitioners, before they planted their 1973 cotton crop, sold that crop to cotton buyers through a cotton gin which contacted them seeking to purchase their cotton. Contracts of sale described petitioner-husband as grower, the gin as seller, and the buyers as buyers, and specified the price to be paid for various grades and staples of cotton, delivery terms, and the cotton gin which would gin the cotton.
Read the full summary
In March 1973, petitioners, before they planted their 1973 cotton crop, sold that crop to cotton buyers through a cotton gin which contacted them seeking to purchase their cotton. Contracts of sale described petitioner-husband as grower, the gin as seller, and the buyers as buyers, and specified the price to be paid for various grades and staples of cotton, delivery terms, and the cotton gin which would gin the cotton. The contract contained no provision as to time of delivery of the cotton or time of payment therefor. In November 1973, petitioner-husband and the gin executed a deferred…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined a deficiency in petitioners’ Federal income tax for their taxable year 1973 in the amount of $11,656.65. After concessions by petitioners, we need only determine the appropriate taxable year in which amounts obtained by petitioners from the sale of cotton should be included in their gross income.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Billy E. Arnwine (herein petitioner) and his wife, Shirley E. Arnwine, filed a joint Federal income tax…
2Cases cited10 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Lubbock Feed Lots, Inc., and Lockney Cooperative Gin v. Iowa Beef Processors, Inc.Court of Appeals for the Fifth Circuit · 1980
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Valley View Cattle Company v. Iowa Beef Processors, Inc.Court of Appeals for the Fifth Circuit · 1977
- Thayer v. Pacific Electric Railway Co.California Supreme Court · 1961
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
- Billy E. Arnwine and Shirley S. Arnwine v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1983
- Arnwine v. CommissionerUnited States Tax Court · 1981
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
- Herndon v. CommissionerUnited States Tax Court · 1986
1 more not listed; retrieve them via the Exa API.