Legal Opinion

Alderson v. Commissioner

United States Tax Court

Decided May 7, 1962No. Docket No. 88988Published

Petitioners entered an escrow to sell farm property B to a corporation. Petitioners wanted to exchange the property for other farm property, and upon finding suitable property S, the escrow agreement was amended to provide the corporation would acquire property S and exchange it for property B. Petitioners entered a second escrow as "buyer" to acquire property S, and paid into that escrow the difference between the greater purchase price of property S and the amount the…

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Petitioners entered an escrow to sell farm property B to a corporation. Petitioners wanted to exchange the property for other farm property, and upon finding suitable property S, the escrow agreement was amended to provide the corporation would acquire property S and exchange it for property B. Petitioners entered a second escrow as "buyer" to acquire property S, and paid into that escrow the difference between the greater purchase price of property S and the amount the corporation had agreed to pay for property B. The corporation paid into the second escrow the amount it had agreed to pay…

1Opinion of the Court

James Alderson, Surviving Husband, and Estate of Clarissa E. Alderson, Deceased, James Alderson, Executor, Petitioners, v. Commissioner of Internal Revenue, Respondent

Alderson v. Commissioner

Docket No. 88988

United States Tax Court

38 T.C. 215; 1962 U.S. Tax Ct. LEXIS 140;

May 7, 1962, Filed

Decision will be entered for the respondent.

Petitioners entered an escrow to sell farm property B to a corporation. Petitioners wanted to exchange the property for other farm property, and upon finding suitable property S, the escrow agreement was amended to provide the corporation would acquire property S…

2Cases cited14 opinions

  1. Griffiths v. CommissionerSupreme Court of the United States · 1939
  2. Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
  3. WD Haden Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
  4. Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
  5. Trenton Cotton Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1945

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