Watson v. Commissioner
United States Board of Tax Appeals
Under the facts and circumstances here the practical effect of the things done constituted a sale of the petitioner's properties for tax purposes, irrespective of a so-called "lease and option agreement" entered into purporting to lease said properties for a term of months with an option to purchase upon expiration of the term for the nominal sum of $1.
1Opinion of the Court
*471OPINION.
MoReis:
The issue .presented by the pleadings is whether the respondent erred in determining that a profit of $79,259.39 was realized by the petitioner during the year 1924 from the alleged sale of certain personalty and bus line operative rights upon the theory that the agreement of lease entered into by the petitioner, under which the property is alleged to have passed, was in fact an agreement of conditional sale.
The petitioner owned, and was engaged in operating, a bus line, which in November, 1922, he agreed to sell, together with his franchise, to the Pickwick Stages, for…
2Cases cited9 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- Heryford v. DavisSupreme Court of the United States · 1880
- Van Allen v. FrancisCalifornia Supreme Court · 1899
- Erving v. Jas. H. Goodman & Co. BankCalifornia Supreme Court · 1915
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Watson v. CommissionerUnited States Board of Tax Appeals · 1931