Hoover v. Commissioner
United States Tax Court
1. Held, petitioners did not hold the properties sold in 1953, 1954, and 1955 for sale to customers in the ordinary course of a trade or business. 2. Held, further, that installment payments on sales of real property made in the years prior to 1953 are not taxable as ordinary income. 3. Held, further, a loss deduction for worthless stock claimed by petitioners in 1953 was properly disallowed. 4. Held, further, respondent did not meet his burden of proving that payments made…
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1. Held, petitioners did not hold the properties sold in 1953, 1954, and 1955 for sale to customers in the ordinary course of a trade or business. 2. Held, further, that installment payments on sales of real property made in the years prior to 1953 are not taxable as ordinary income. 3. Held, further, a loss deduction for worthless stock claimed by petitioners in 1953 was properly disallowed. 4. Held, further, respondent did not meet his burden of proving that payments made by petitioners to an employee of the Land Trust of Missouri were contrary to public policy and, therefore, not…
1Opinion of the Court
MulROney, Judge:
Respondent determined deficiencies in the petitioners’ income tax as follows:
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68417 James G. and Edna Hoover, f1953.... $10,291.40 1954_ 11,149.00 1.1955.. 16, 414. 93
f 1953_ 2,021.94 68418 Charles A. and Della Hoover_j 1954_ 458. 28 ll955.. 327. 05
In an amendment to the answer the respondent claimed additional deficiencies in the petitioners’ income tax as follows :
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$2, 266. 84 _ 5,711.69 68417. Í1953. 11955.
_ 1,736.92 .. 71. 85 68418. f1953. 11955-
The issues in these consolidated cases are:(1) Whether the gains realized from the sales of real estate…
2Cases cited7 opinions
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Thrift v. CommissionerUnited States Tax Court · 1950
- Farley v. CommissionerUnited States Tax Court · 1946
- Boomhower v. United StatesDistrict Court, N.D. Iowa · 1947
2 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- Pritchett v. CommissionerUnited States Tax Court · 1974
- Howell v. CommissionerUnited States Tax Court · 1972
- Real Estate Corp. v. CommissionerUnited States Tax Court · 1961
- Aagaard v. CommissionerUnited States Tax Court · 1971
- Mitchell v. CommissionerUnited States Tax Court · 1966
47 more not listed; retrieve them via the Exa API.