Legal Opinion

Ward v. Commissioner

United States Tax Court

Decided July 16, 1986No. Docket No. 30068-83Published

In 1940, H entered into a land contract to purchase ranch land in Florida. Over the next 4 years, H and his wife, W, each contributed indeterminate amounts of money to pay the installments of the purchase price of the ranch land and to acquire an adjacent parcel of ranch land. H took title to both parcels in his name alone. In 1978, H and W deeded the ranch land to a newly formed corporation, J, except for three small plots deeded as gifts to their sons and their wives.

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In 1940, H entered into a land contract to purchase ranch land in Florida. Over the next 4 years, H and his wife, W, each contributed indeterminate amounts of money to pay the installments of the purchase price of the ranch land and to acquire an adjacent parcel of ranch land. H took title to both parcels in his name alone. In 1978, H and W deeded the ranch land to a newly formed corporation, J, except for three small plots deeded as gifts to their sons and their wives. In return for the ranch, H and W each received 43.7 percent of the stock in J. The three sons of H and W contributed cattle…

1Opinion of the Court

Charles W. Ward and Virginia P. Ward, Petitioners v. Commissioner of Internal Revenue, Respondent

Ward v. Commissioner

Docket No. 30068-83

United States Tax Court

87 T.C. 78; 1986 U.S. Tax Ct. LEXIS 81; 87 T.C. No. 6;

July 16, 1986, Filed

Decision will be entered under Rule 155.

In 1940, H entered into a land contract to purchase ranch land in Florida. Over the next 4 years, H and his wife, W, each contributed indeterminate amounts of money to pay the installments of the purchase price of the ranch land and to acquire an adjacent parcel of ranch land. H took title to both parcels in his name alone.…

2Cases cited91 opinions

  1. Canakaris v. CanakarisSupreme Court of Florida · 1980
  2. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  3. Morgan v. CommissionerSupreme Court of the United States · 1940
  4. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  5. Estate of Sanford v. CommissionerSupreme Court of the United States · 1939

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