Strong v. Commissioner
United States Tax Court
Petitioners acquired gilts and calves as rental payments from their closely held farm corporations. Held, petitioners must recognize rental income on their transfers of gilts and calves to their leased breeding herds. Held, further, the amount of rental income recognized is determined in accordance with the lease agreements.
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Petitioner TYE Dec. 31— Deficiency
Duane and Sara Strong 1982 $1,501
Gary and Marlys Karkosh 1981 436
The primary issue for our determination is whether petitioners were correct in not reporting any rental income from their acquisitions of livestock which they designated as replacements or additions to their breeding herds.
FINDINGS OF FACT
Some of the facts are stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Petitioners…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
- United States v. DavisSupreme Court of the United States · 1962
28 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Applegate v. CommissionerUnited States Tax Court · 1990
- Dudden v. CommissionerUnited States Tax Court · 1988
- Applegate v. CommissionerUnited States Tax Court · 1990
- Dudden v. CommissionerUnited States Tax Court · 1988
- Roger P. Dudden and Marcia Dudden v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 1990
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