Legal Opinion

Robinson v. Commissioner

United States Board of Tax Appeals

Decided July 28, 1933No. Docket No. 50302PublishedCited by 3 opinions

1. In the early part of 1927 the petitioner sold certain shares of stock, which cost him $45,000, for $87,500, receiving in payment therefor $17,500 in cash and sixteen promissory notes, four payable on the first of March of each of the years 1928, 1929, 1930 and 1931, each four aggregating $17,500. Later in the year 1927, the petitioner, in part payment of certain real estate then purchased by him, transferred at their face value the eight notes having the earliest maturity…

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1. In the early part of 1927 the petitioner sold certain shares of stock, which cost him $45,000, for $87,500, receiving in payment therefor $17,500 in cash and sixteen promissory notes, four payable on the first of March of each of the years 1928, 1929, 1930 and 1931, each four aggregating $17,500. Later in the year 1927, the petitioner, in part payment of certain real estate then purchased by him, transferred at their face value the eight notes having the earliest maturity dates. Held, the petitioner is not entitled to report the profit realized from the sale of his stock on an installment…

1Opinion of the Court

OPINION.

Seawell:

The respondent determined a deficiency in income tax of $3,597.28 against the petitioner for the year 1927. In an amended *789answer be prays to have petitioner’s taxable income for tbat year increased in tlie amount of $3,638.27, due to the petitioner’s alleged failure to report the entire proceeds from the sale of the stock of the Molalla Electric Co. during the year 1927.

The petitioner assigned two errors: (1) That the respondent failed or refused to compute the tax upon the profit realized from the sale of aforesaid stock upon the installment basis, and (2) that the respondent…

2Cases cited1 opinion

  1. Chapman v. CommissionerUnited States Board of Tax Appeals · 1930

3Cited by3 opinions

  1. Branham v. CommissionerUnited States Tax Court · 1968
  2. Branham v. CommissionerUnited States Tax Court · 1968
  3. Robinson v. CommissionerUnited States Board of Tax Appeals · 1933

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