Townsend v. Commissioner
United States Tax Court
Payments made in subsequent years under a contract of sale of corporate stock calling for a total specified maximum payment but not to exceed a stipulated percentage of the corporation's income for the following 5 years, held to be proceeds of the sale and thus taxable to the sellers notwithstanding that the unfulfilled portion of the sales contract had in the meantime been made the subject of a gift.
1Opinion of the Court
Stephen S. Townsend and Margery B. Townsend, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Townsend v. Commissioner
Docket Nos. 86991, 93525, 93526
United States Tax Court
37 T.C. 830; 1962 U.S. Tax Ct. LEXIS 201;
January 30, 1962, Filed
Decisions will be entered under Rule 50.
Payments made in subsequent years under a contract of sale of corporate stock calling for a total specified maximum payment but not to exceed a stipulated percentage of the corporation's income for the following 5 years, held to be proceeds of the sale and thus taxable to the sellers notwithstanding…
2Cases cited20 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Burnet v. LoganSupreme Court of the United States · 1931
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