Legal Opinion

Lewis v. Commissioner

United States Tax Court

Decided April 4, 1968No. Docket Nos. 4449-62, 158-63, 3537-65Unpublished

Petitioner, Ralph R. Lewis, entered into agreements with the Jenkins family to purchase all of the stock of West Virginia Northern Railroad Co. for $500,000, payable over a period of years, with the Railroad stock to be collateral security for payment of the note evidencing the purchase price.

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Petitioner, Ralph R. Lewis, entered into agreements with the Jenkins family to purchase all of the stock of West Virginia Northern Railroad Co. for $500,000, payable over a period of years, with the Railroad stock to be collateral security for payment of the note evidencing the purchase price. Concurrent therewith Railroad entered into an agreement with the Jenkins family modifying a lease of two diesel locomotives by Railroad from the Jenkins family under which the "rental" was increased from 7 1/2 cents per ton of coal hauled to 12 1/2 cents per ton, with the additional 5 cents to be…

1Opinion of the Court

Ralph R. Lewis and Dorothea G. Lewis, et al., 1 v. Commissioner.

Lewis v. Commissioner

Docket Nos. 4449-62, 158-63, 3537-65.

United States Tax Court

T.C. Memo 1968-56; 1968 Tax Ct. Memo LEXIS 241; 27 T.C.M. (CCH) 292; T.C.M. (RIA) 68056;

April 4, 1968. Filed

Petitioner, Ralph R. Lewis, entered into agreements with the Jenkins family to purchase all of the stock of West Virginia Northern Railroad Co. for $500,000, payable over a period of years, with the Railroad stock to be collateral security for payment of the note evidencing the purchase price. Concurrent therewith Railroad entered into an…

2Cases cited32 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
  3. Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
  4. Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
  5. American Properties, Inc. v. CommissionerUnited States Tax Court · 1957

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