Bellamy v. Commissioner
United States Tax Court
Held, that an amount received by the petitioner did not represent proceeds from the sale of a capital asset, and that such amount is taxable as ordinary income.
1Opinion of the Court
AteiNS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1957 in the amount of $44,864.77.
The parties having reached agreement as to certain issues, the issue remaining for decision is whether the sum of $89,000 paid to the petitioner Ralph Bellamy in 1957 was proceeds from the sale by him of property which was a capital asset, resulting in the receipt of long-term capital gain as contended by him, or is taxable as ordinary income as determined by the respondent.
FINDINGS OF FACT
Some of the facts have been stipulated and are incorporated herein by this reference.
T…
2Cases cited13 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
8 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Hill v. CommissionerUnited States Tax Court · 1967
- Michot v. CommissionerUnited States Tax Court · 1982
- Bellamy v. CommissionerUnited States Tax Court · 1965
- Edwards v. CommissionerUnited States Tax Court · 1968
- Edwards v. CommissionerUnited States Tax Court · 1968
1 more not listed; retrieve them via the Exa API.