Edgar v. Commissioner
United States Tax Court
1. Neither the individual petitioners who are members of the Strain family nor the trusts which they created in 1963 had recognizable capital gain in 1964 (other than the gain referred to in issue 2) when stock was sold to Brigham Young University; the transaction was not an exchange of stock for annuities, but was a deferred-payment sale by the trusts. 2. Neither William Russell Strain nor Harriet Strain realized taxable income in 1964 on the sale by two trusts of stock…
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1. Neither the individual petitioners who are members of the Strain family nor the trusts which they created in 1963 had recognizable capital gain in 1964 (other than the gain referred to in issue 2) when stock was sold to Brigham Young University; the transaction was not an exchange of stock for annuities, but was a deferred-payment sale by the trusts. 2. Neither William Russell Strain nor Harriet Strain realized taxable income in 1964 on the sale by two trusts of stock which was subject to liens, securing notes previously given by William Russell Strain and Arthur W. Strain; however, the…
1Opinion of the Court
FeathekstoN, Judge:
Respondent determined deficiencies in petitioners’ income tax and additions to tax under sections 6651(a) 2 and 6653(a) as follows:
Docket No. Taxable Additions to tax year Amount-Sec. 6651(a) Sec.6653(a)
3237-67. Í1962 $23,914.44. (1963 17,153.34 .
3340-67. 1963 16,484.29 .
3341-67. 1903 15,176.11 .
2911-68. 1964 179,042.72 .
2912-68.. 1964 144,048.91 .
2913-68.. 1964 40,817.77 .
2914-68. 1964 68,179.28 .
2915-68. 1964 57,308.14 .
2916-68. 1964 95,970.48 $23,992.62 .
2917-68.. 1964 87,267.20 21,816.80 .
2918-68.. 1964 105,971.52 26,492.88 .
2919-68.. 1964 40,478.31 10,119.57 .
2920-68.…
2Cases cited68 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. LoBueSupreme Court of the United States · 1956
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3Cited by51 opinions
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- La Fargue v. CommissionerUnited States Tax Court · 1979
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