Bowyer v. Commissioner
United States Tax Court
Petitioner, on March 6, 1953, acquired a going business which consisted of publishing and selling an annual city directory. Held, petitioner acquired the business by gift and his basis in the uncompleted copies at the time of the gift was $ 3,000, which sum is to be deducted from the proceeds received from the sale of the directories ($ 28,361.52) in the year 1953, in computing his gross income for that year.
1Opinion of the Court
Mulroney, Judge:
Respondent determined a deficiency in petitioners’ income tax of $3,686.58 for the taxable year 1952 and $3,838.76 for the taxable year 1953. Bespondent amended his answer to claim an additional deficiency of $472.58 for the year 1953. The only issue to be decided is whether any portion of $28,361.52, the proceeds received from the sale of copies of a city directory during the year 1953, is includible in petitioners’ gross income for that year.
FINDINGS OF FACT.
Some of the facts have been stipulated and they are found accordingly.
For about 18 years prior to 1953 J. H. (Jack)…
2Cases cited4 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Rev. v. Vandegrift R. & Inv. Co.Court of Appeals for the Ninth Circuit · 1936
- Zenith Sportswear Co. v. CommissionerUnited States Tax Court · 1957
3Cited by5 opinions
- Du Pasquier v. CommissionerUnited States Tax Court · 1963
- Long Island Water Corp. v. CommissionerUnited States Tax Court · 1961
- Bowyer v. CommissionerUnited States Tax Court · 1960
- Long Island Water Corp. v. CommissionerUnited States Tax Court · 1961
- Long Island Water Corp. v. CommissionerUnited States Tax Court · 1961