Legal Opinion

Nutt v. Commissioner

United States Tax Court

Decided October 26, 1962No. Docket Nos. 77669, 77670PublishedCited by 24 opinions

Petitioners, who have been farmers since 1935, carried on their farming operations prior to August 30, 1955, on approximately 2,400 acres of farmland which they owned and additional land which they leased.

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Petitioners, who have been farmers since 1935, carried on their farming operations prior to August 30, 1955, on approximately 2,400 acres of farmland which they owned and additional land which they leased. On August 25, 1955, they formed a corporation in which they owned all the voting stock (150 issued shares, par value $ 100), and their accountant and lawyer each owned one share of nonvoting stock (par value $ 100). On August 30, 1955, they conveyed approximately 1,142 acres of their farmland planted in mature but unharvested cotton to this corporation for a consideration of $ 324,933.13 of…

1Opinion of the Court

Scott, Judge:

Respondent determined deficiencies in petitioners’ income tax for the years and in the amounts as follows:

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By amendment to answer respondent asserted an alternative position and claimed an increased deficiency for the year 1957 in the case of John F. Nutt in the amount of $8,413.85 and in the case of Eileen M. Nutt in the amount of $8,413.85.

The issues for decision are:(1) Whether petitioners’ sales of land with unharvested crops thereon to Rancho Tierra Prieta, a corporation in which they held all the voting stock, and assignment of leaseholds with unharvested crops…

2Cases cited17 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Lucas v. EarlSupreme Court of the United States · 1930
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  5. Higgins v. SmithSupreme Court of the United States · 1940

12 more not listed; retrieve them via the Exa API.

3Cited by24 opinions

  1. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  2. Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
  3. Bass v. CommissionerUnited States Tax Court · 1968
  4. Beckett v. CommissionerUnited States Tax Court · 1963
  5. Bijou Park Properties, Inc. v. CommissionerUnited States Tax Court · 1966

19 more not listed; retrieve them via the Exa API.

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