George L. Castner Co. v. Commissioner
United States Tax Court
George L. Castner Company, Inc., was engaged in the milk and ice cream business, and in the taxable year sold its machinery and equipment, receiving therefor $ 3,000 in cash and an interest-bearing note in the principal amount of $ 8,000, payable quarter-annually over a period of 10 years. The cash, plus the subsequent payments on principal received in the year of sale, represented more than 30 per cent of the selling price.
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George L. Castner Company, Inc., was engaged in the milk and ice cream business, and in the taxable year sold its machinery and equipment, receiving therefor $ 3,000 in cash and an interest-bearing note in the principal amount of $ 8,000, payable quarter-annually over a period of 10 years. The cash, plus the subsequent payments on principal received in the year of sale, represented more than 30 per cent of the selling price. Held, that the $ 8,000 evidenced by the note was an accrued receivable at the date of the sale and, the taxpayer being on an accrual basis of accounting for reporting…
1Opinion of the Court
The respondent determined deficiencies in income tax against the petitioners as follows:
Docket No. . Year Deficiency
65774 George L. Castner Company, Inc_ 1951 $341. 66
55775 George L. Castner and Lucile C. Castner_ 1952. 831. 32
The questions for decision are whether the respondent erred (1) in his determination of the 1951 gain realized by George L. Castner Company, Inc., from the sale of certain machinery and equipment, and (2) in his determination of fair market value of a note George L. Castner received in liquidation of his George L. Castner Company, Inc., stock.
FINDINGS OF FACT.
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2Cases cited13 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. CaldwellCourt of Appeals for the Second Circuit · 1953
- Aluminum Castings Co. v. RoutzahnSupreme Court of the United States · 1930
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
- Bedell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
8 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Western Oaks Bldg. Corp. v. CommissionerUnited States Tax Court · 1968
- Jones Lumber Co., Inc. v. Commissioner of Internal Revenue, Rach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- Baltimore Baseball Club, Inc. v. United StatesUnited States Court of Claims · 1973
- Johnson v. CommissionerUnited States Tax Court · 1982
- Freitas v. CommissionerUnited States Tax Court · 1966
8 more not listed; retrieve them via the Exa API.