Wilson v. Commissioner
United States Tax Court
Held, that under the contract pursuant to which the Valley Lumber Company, a partnership, acquired a tract of timber known as the Vaughan timber, such partnership would, under Oregon law, be deemed the equitable owner thereof; that its subsequent cutting arrangement with its controlled corporation constituted a "disposal" of the timber within the scope and intendment of section 117(k) (2), I. R. C. 1939; and that petitioners' distributable shares of the partnership's profits…
Read the full summary
Held, that under the contract pursuant to which the Valley Lumber Company, a partnership, acquired a tract of timber known as the Vaughan timber, such partnership would, under Oregon law, be deemed the equitable owner thereof; that its subsequent cutting arrangement with its controlled corporation constituted a "disposal" of the timber within the scope and intendment of section 117(k) (2), I. R. C. 1939; and that petitioners' distributable shares of the partnership's profits therefrom are properly taxable as long-term capital gains.
1Opinion of the Court
L. D. Wilson and Jane Wilson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Wilson v. Commissioner
Docket No. 53094
United States Tax Court
26 T.C. 474; 1956 U.S. Tax Ct. LEXIS 171;
June 7, 1956, Filed
Decision will be entered for the petitioners.
Held, that under the contract pursuant to which the Valley Lumber Company, a partnership, acquired a tract of timber known as the Vaughan timber, such partnership would, under Oregon law, be deemed the equitable owner thereof; that its subsequent cutting arrangement with its controlled corporation constituted a "disposal" of the timber…
2Cases cited16 opinions
- S. R. A., Inc. v. MinnesotaSupreme Court of the United States · 1946
- City of New Brunswick v. United StatesSupreme Court of the United States · 1928
- Anderson v. Miami Lumber Co.Oregon Supreme Court · 1911
- Flanagan Estate v. Great Cent. Land Co.Oregon Supreme Court · 1904
- Rayburn Et Ux. v. Crawford Et Ux.Oregon Supreme Court · 1949
11 more not listed; retrieve them via the Exa API.