Hudson v. Commissioner
United States Tax Court
Capital Gain -- Ordinary Income -- Section 117 (a) (4). -- Petitioners purchased a judgment from the residuary legatees of an estate; later, petitioners settled the judgment with the judgment debtor. Held, the gain realized by petitioners was not gain realized from the sale or exchange of a capital asset.
1Opinion of the Court
Galvin Hudson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Hillsman Taylor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Hudson v. Commissioner
Docket Nos. 43190, 43191
United States Tax Court
20 T.C. 734; 1953 U.S. Tax Ct. LEXIS 99;
June 30, 1953, Promulgated
Decisions will be entered under Rule 50.
Capital Gain -- Ordinary Income -- Section 117 (a) (4). -- Petitioners purchased a judgment from the residuary legatees of an estate; later, petitioners settled the judgment with the judgment debtor. Held, the gain realized by petitioners was not gain realized from the…
2Cases cited13 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Commissioner of Internal Revenue v. Golonsky. Commissioner of Internal Revenue v. GoldCourt of Appeals for the Third Circuit · 1952
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Golonsky v. CommissionerUnited States Tax Court · 1951
- Ray v. CommissionerUnited States Tax Court · 1952
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