Legal Opinion

Biggs v. Commissioner

United States Tax Court

Decided March 13, 1978No. Docket No. 7272-75Published

T orally agreed to sell his Maryland farm to P for $ 900,000; as part of the consideration, T was to receive like kind property. Subsequently, T located a Virginia farm which he wished to receive in exchange, arranged for title to the Virginia farm to be transferred to C, and advanced the necessary funds.

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T orally agreed to sell his Maryland farm to P for $ 900,000; as part of the consideration, T was to receive like kind property. Subsequently, T located a Virginia farm which he wished to receive in exchange, arranged for title to the Virginia farm to be transferred to C, and advanced the necessary funds. Later, P contracted to buy the Virginia farm from C. On the following day, by written contract, T agreed to transfer the Maryland farm to P, and P assigned his right to purchase the Virginia farm to T. At the closing of these transactions, T conveyed his Maryland farm to P's assigns and…

1Opinion of the Court

Franklin B. Biggs, Petitioner v. Commissioner of Internal Revenue, Respondent

Biggs v. Commissioner

Docket No. 7272-75

United States Tax Court

69 T.C. 905; 1978 U.S. Tax Ct. LEXIS 158;

March 13, 1978, Filed

Decision will be entered under Rule 155.

T orally agreed to sell his Maryland farm to P for $ 900,000; as part of the consideration, T was to receive like kind property. Subsequently, T located a Virginia farm which he wished to receive in exchange, arranged for title to the Virginia farm to be transferred to C, and advanced the necessary funds. Later, P contracted to buy the Virginia farm from…

2Cases cited21 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Weiss v. StearnSupreme Court of the United States · 1924
  5. June Pinson Carlton and Charles T. Carlton, as Administrators of the Estate of Thad H. Carlton, and June Carlton v. United StatesCourt of Appeals for the Fifth Circuit · 1967

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