Baker v. Commissioner
United States Tax Court
Petitioner Neil K. Baker owned and operated a barter exchange. Held, trade units received as commissions on transactions occurring within the barter exchange are taxable to petitioner at a value of $ 1 each.
1Opinion of the Court
SWIFT, Judge:
In a statutory notice of deficiency dated January 17, 1984, respondent determined deficiencies in petitioners’ Federal income tax liabilities for 1976 through 1979 as follows:
Year Deficiency
1976 . $913
1977 . 581
1978 . 4,298
1979 . 2,851
These deficiencies arise from respondent’s disallowance of a net operating loss reported on petitioners’ 1981 joint Federal income tax return. After concessions, the primary issue for decision is the proper value of trade units received by petitioner Neil K. Baker as the owner of a barter exchange.
FINDINGS OF FACT
Some of the facts have been…
2Cases cited8 opinions
- In the Matter of the Tax Liabilities of John Does, Members of the Columbus Trade Exchange in the Years 1977 and 1978 United States of AmericaCourt of Appeals for the Sixth Circuit · 1982
- Verlin W. And Anna Jo Koons v. United States of America, Charles H. And Cecelia Parker v. United StatesCourt of Appeals for the Ninth Circuit · 1963
- United States of America and Gerald R. Potocnak, Revenue Agent, Internal Revenue Service v. Pittsburgh Trade Exchange Inc. And Vincent E. ManellaCourt of Appeals for the Third Circuit · 1981
- United States of America and Edward H. Jackson, Revenue Agent, Internal Revenue Service v. Herbert Gottlieb and the Florida Trade Exchange, Inc.Court of Appeals for the Eleventh Circuit · 1983
- Rooney v. CommissionerUnited States Tax Court · 1987
3 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- G.M. Trading Corp. v. CommissionerUnited States Tax Court · 1996
- Waltner v. Comm'rUnited States Tax Court · 2014
- Barter Systems, Inc. v. CommissionerUnited States Tax Court · 1990
- Exchange Enterprises of Salt Lake, Inc. v. CommissionerUnited States Tax Court · 1987
- Badell v. CommissionerUnited States Tax Court · 2000
6 more not listed; retrieve them via the Exa API.