Legal Opinion

Stone v. Commissioner

United States Tax Court

Decided April 17, 1968No. Docket Nos. 3395-66, 3399-66, 3400-66, 3401-66PublishedCited by 8 opinions

Effective Oct. 1, 1958, the following events took place: (1) Halbouty transferred undivided interests in certain oil and gas leases to Scripps for $ 2,750,000, $ 240,000 of which was allocated to certain equipment and personal property. (2) In order to finance this acquisition, Scripps obtained a $ 2,500,000 loan with interest at 5 1/2 percent from the bank giving in exchange its demand note.

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Effective Oct. 1, 1958, the following events took place: (1) Halbouty transferred undivided interests in certain oil and gas leases to Scripps for $ 2,750,000, $ 240,000 of which was allocated to certain equipment and personal property. (2) In order to finance this acquisition, Scripps obtained a $ 2,500,000 loan with interest at 5 1/2 percent from the bank giving in exchange its demand note. In order to secure payment of the note, Scripps assigned to the bank a deed of trust and an assignment of production from the property. (3) Scripps then conveyed the working interest in the property and…

1Opinion of the Court

Fat, Judge:

The statutory notices issued in these cases involve deficiencies in income taxes in docket No. 3395-66 and duplicate transferee notices of liability in docket Nos. 3399-66 and 3401-66. The Court granted respondent’s motion to file amended answers in docket Nos. 3395-66,3399-66,and 3401-66.

The liabilities and deficiencies in income taxes for the various years in the respective dockets as per the statutory notices and also respondent’s amended answers areas follows:

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The statutory notice in docket No. 3400-66 involves a deficiency in estate tax in the amount of $65,520.13.

2Cases cited5 opinions

  1. Anderson v. HelveringSupreme Court of the United States · 1940
  2. Thomas v. PerkinsSupreme Court of the United States · 1937
  3. Bryant v. CommissionerUnited States Tax Court · 1966
  4. Hibler v. CommissionerUnited States Tax Court · 1966
  5. Driscoll v. CommissionerUnited States Tax Court · 1944

3Cited by8 opinions

  1. Landreth v. CommissionerUnited States Tax Court · 1968
  2. Finley W. Holbrook and Faith Holbrook v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  3. Holbrook v. CommissionerUnited States Tax Court · 1970
  4. Finley W. Holbrook and Faith Holbrook v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  5. Holbrook v. CommissionerUnited States Tax Court · 1970

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