Legal Opinion
Lloyd Patterson and Charlene Patterson v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 27, 1975No. 73--2728PublishedCited by 5 opinions
1Opinion of the Court
OPINION
MILLER, Judge:
This is an appeal by the taxpayers, husband and wife, from a decision of the United States Tax Court (TC Memo 1973 — 39) determining a deficiency in income tax for calendar year 1969 for which they filed a joint return on the cash basis. As pointed out by the Tax Court, the only issue between the parties is whether appellants constructively received in 1969 an $18,000 payment which was actually received on January 5, 1970.
The Pattersons were residents of Idaho, where Lloyd Patterson (hereinafter “Patterson”) engaged in farming. On June 17, 1969, he entered into a “Potato…
2Cases cited4 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Romine v. Comm'rUnited States Tax Court · 1956
- R. Guy Bennett and R. Guy Bennett, of the Estate of Mildred Bennett, Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1961
3Cited by5 opinions
- Levno v. United StatesDistrict Court, D. Montana · 1977
- Estate of Shelton v. CommissionerUnited States Tax Court · 1977
- Estate of Jacqueline E. Shelton, Deceased, Donald C. Little and Johnnie Mohon, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1980
- Estate of Shelton v. CommissionerUnited States Tax Court · 1977
- Rutland v. CommissionerUnited States Tax Court · 1977