Legal Opinion
GARDENS OF FAITH, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Court of Appeals for the Fourth Circuit
Decided March 18, 1965No. 9714, 9715PublishedCited by 10 opinions
1Per curiam
Raymond F. Cushing and wife were instrumental in organizing two cemetery corporations, Gardens of Faith, Inc., and Evergreen Memorial Gardens, Inc. The corporations issued certain “Certificates of Indebtedness” for undetermined amounts, which required them to pay to the certificate holders 25% of the base sales price of every burial lot sold by the corporations for 50 years.
The issues in this appeal are the appropriate tax treatment of the sums thus paid, both in the corporations’ returns and those of the certificate holders, Cush ing and wife. The Commissioner of Internal Revenue contends…
2Cited by10 opinions
- Knollwood Memorial Gardens v. CommissionerUnited States Tax Court · 1966
- Sherwood Memorial Gardens, Inc., (Tennessee) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
- Rose Hills Memorial Park Ass'n v. United StatesUnited States Court of Claims · 1972
- William S. Peterson and Betty M. Peterson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967
- Knollwood Memorial Gardens v. CommissionerUnited States Tax Court · 1966
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