Robinson v. Commissioner
United States Tax Court
On Jan. 10, 1964, the petitioner sold his business under a contract providing for payments in installments without interest. At that time, the transaction met all the requirements of sec. 453(b) of the Internal Revenue Code of 1954 for the reporting of the gain on the installment method.
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On Jan. 10, 1964, the petitioner sold his business under a contract providing for payments in installments without interest. At that time, the transaction met all the requirements of sec. 453(b) of the Internal Revenue Code of 1954 for the reporting of the gain on the installment method. On Feb. 26, 1964, Congress enacted sec. 483 of the Code which provided that, for purposes of the Code, where no interest payments are specified with respect to certain installment payments, a part of each installment payment shall be treated as interest. It was provided that sec. 483 should apply to payments…
1Opinion of the Court
OPINION
On January 10,1964, the petitioner sold his business on the installment plan. The terms of the sale complied in all respects with the requirements of section 453 (b) of the Internal Revenue Code of 1954,3 relating to the reporting of gain on the installment method. The payments to be received in the taxable year of sale did not exceed 30 percent of the stated selling price. However, the contract of sale provided that no interest should be paid on the deferred payments.
On February 26, 1964, Congress enacted section 224(a) of the Revenue Act of 1964, which added section 483 (set forth…
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- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Chew Heong v. United StatesSupreme Court of the United States · 1884
- Fullerton-Krueger Lumber Co. v. Northern Pacific Railway Co.Supreme Court of the United States · 1925
- Twenty Per Cent. CasesSupreme Court of the United States · 1874
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3Cited by7 opinions
- Rose v. CommissionerUnited States Tax Court · 1970
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