Carpenter v. Commissioner
United States Tax Court
Petitioners, partners in a logging business, entered into an agreement on January 21, 1953, with persons who held option to purchase timber from a company which claimed to be owner thereof even though the title was involved in litigation. Agreement provided that if consent of the claimed owner could be obtained logging would be commenced without the partnership being required to exercise the option. Such consent was obtained on January 30, 1953, and logging began.
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Petitioners, partners in a logging business, entered into an agreement on January 21, 1953, with persons who held option to purchase timber from a company which claimed to be owner thereof even though the title was involved in litigation. Agreement provided that if consent of the claimed owner could be obtained logging would be commenced without the partnership being required to exercise the option. Such consent was obtained on January 30, 1953, and logging began. The other claimant to title to the timber obtained a temporary injunction against logging by the partnership and the partnership…
1Opinion of the Court
James A. Carpenter and Cloris A. Carpenter, Petitioners, v. Commissioner of Internal Revenue, Respondent. Richard E. Nealy and Verda Nealy, Petitioners, v. Commissioner of Internal Revenue, Respondent
Carpenter v. Commissioner
Docket Nos. 79509, 79510
United States Tax Court
36 T.C. 797; 1961 U.S. Tax Ct. LEXIS 104;
July 31, 1961, Filed
Decision will be entered under Rule 50.
Petitioners, partners in a logging business, entered into an agreement on January 21, 1953, with persons who held option to purchase timber from a company which claimed to be owner thereof even though the title was involved in…
2Cases cited13 opinions
- George L. Jantzer Et At. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Springfield Plywood Corp. v. CommissionerUnited States Tax Court · 1950
- Ah Pah Redwood Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Ah Pah Redwood Co. v. CommissionerUnited States Tax Court · 1956
- Joe S. Ray v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1960
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