Applegate v. Commissioner
United States Tax Court
During 1984, P, as a landlord farmer, sold grain crop share rentals for $ 83,280.79 and entered into contracts for future payments, the price of which was fixed at the market value 1 year after the execution of the contracts, subject to P's right to accelerate the time for establishing the price and for payment.
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During 1984, P, as a landlord farmer, sold grain crop share rentals for $ 83,280.79 and entered into contracts for future payments, the price of which was fixed at the market value 1 year after the execution of the contracts, subject to P's right to accelerate the time for establishing the price and for payment. Held, the contracts did not constitute an evidence of indebtedness "payable on demand" within the meaning of sec. 453(f)(4)(A), I.R.C., and therefore did not constitute a "payment" under sec. 453(f)(3) with the result that the transactions qualify as an installment sale under sec.…
1Opinion of the Court
Calvin P. Applegate and Irma Applegate, Petitioners v. Commissioner of Internal Revenue, Respondent
Applegate v. Commissioner
Docket No. 12721-88
United States Tax Court
94 T.C. 696; 1990 U.S. Tax Ct. LEXIS 47; 94 T.C. No. 42;
May 16, 1990, Filed
Decision will be entered under Rule 155.
During 1984, P, as a landlord farmer, sold grain crop share rentals for $ 83,280.79 and entered into contracts for future payments, the price of which was fixed at the market value 1 year after the execution of the contracts, subject to P's right to accelerate the time for establishing the price and for payment.…
2Cases cited8 opinions
- Service Bolt & Nut Co. Profit Sharing Trust v. CommissionerUnited States Tax Court · 1982
- Clyde G. Tatum and Veta Rae Tatum v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Tatum v. CommissionerUnited States Tax Court · 1966
- Ben F. Parmer and Mildred Helen Parmer v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1972
- Strong v. CommissionerUnited States Tax Court · 1988
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