Maher v. Commissioner
United States Tax Court
1. Taxpayer by agreement paid part cash and executed two promissory notes for all of the stock of corporations A, B, C, and D, which stock was then placed in escrow to secure payment of the notes and performance of the agreement. Thereafter and during escrow, taxpayer assigned to A all of his "right, title and interest" in the stock of B in return for A's assumption of liability on his notes; however, taxpayer was not released from such liability.
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1. Taxpayer by agreement paid part cash and executed two promissory notes for all of the stock of corporations A, B, C, and D, which stock was then placed in escrow to secure payment of the notes and performance of the agreement. Thereafter and during escrow, taxpayer assigned to A all of his "right, title and interest" in the stock of B in return for A's assumption of liability on his notes; however, taxpayer was not released from such liability. Thereafter A made payments of principal and of interest on the notes in 1965, 1966, and 1967, such payments fully discharging the notes in 1967. A…
1Opinion of the Court
* Ray A. Maher and Rose M. Maher, Petitioners v. Commissioner of Internal Revenue, Respondent; * Ray A. Maher, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent
Maher v. Commissioner
Docket Nos. 2916-67, 4667-69, 4668-69
United States Tax Court
55 T.C. 441; 1970 U.S. Tax Ct. LEXIS 14;
December 10, 1970, Filed
Decisions will be entered under Rule 50.
1. Taxpayer by agreement paid part cash and executed two promissory notes for all of the stock of corporations A, B, C, and D, which stock was then placed in escrow to secure payment of the notes and performance of the agreement.…
2Cases cited20 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- United States v. DavisSupreme Court of the United States · 1970
- United States v. HendlerSupreme Court of the United States · 1938
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