Vaughn v. Commissioner
United States Tax Court
In Vaughn v. Commissioner, 81 T.C. 893 (1983), we held that certain installment sales by petitioners to petitioner-wife's son were bona fide and should be given tax effect in accordance with the forms of the transactions. However, we also held that petitioner-husband constructively received the proceeds of petitioner-wife's son's subsequent sale of the assets of a corporation that petitioner-husband had sold to the son.
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In Vaughn v. Commissioner, 81 T.C. 893 (1983), we held that certain installment sales by petitioners to petitioner-wife's son were bona fide and should be given tax effect in accordance with the forms of the transactions. However, we also held that petitioner-husband constructively received the proceeds of petitioner-wife's son's subsequent sale of the assets of a corporation that petitioner-husband had sold to the son. Petitioner-husband had sold the corporation under a contract that required the son to place into escrow the proceeds from any sale by him of the assets of the corporation.…
1Opinion of the Court
SUPPLEMENTAL OPINION
CHABOT, Judge:
This case is before us on petitioners’ motion for reconsideration of our opinion in the above-entitled case set forth at 81 T.C. 893 (1983) (hereinafter sometimes referred to as Vaughn I). See Rule 161, Tax Court Rules of Practice and Procedure. In Vaughn I, we made findings of fact which we adopt for purposes of this supplemental opinion. However, for clarity, we begin with a brief recital of the facts pertinent to this supplemental opinion.
For some time before 1973, petitioner Charles L. Vaughn (hereinafter sometimes referred to as Charles) owned all of the…
2Cases cited8 opinions
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
- Zuanich v. CommissionerUnited States Tax Court · 1981
- Estate of Bailly v. CommissionerUnited States Tax Court · 1983
- Louisville and Nashville Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
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3Cited by48 opinions
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- Estate of Halas v. CommissionerUnited States Tax Court · 1990
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- Estate of Turner v. Comm'rUnited States Tax Court · 2012
- Zapara v. Comm'rUnited States Tax Court · 2006
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