Hager v. Commissioner
United States Tax Court
In 1971, Ps became limited partners of X. At the same time, X purchased 107 head of imported cattle from Y, a related entity, for $ 1,614,000. As consideration for the purchase, X paid $ 20,000 in cash, executed a short-term note for $ 529,000 on which it was liable, and executed a nonrecourse promissory note, secured by the cattle, for $ 1,065,000. In 1971, there was no established market price in the United States for such cattle, but during that year, such cattle normally…
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In 1971, Ps became limited partners of X. At the same time, X purchased 107 head of imported cattle from Y, a related entity, for $ 1,614,000. As consideration for the purchase, X paid $ 20,000 in cash, executed a short-term note for $ 529,000 on which it was liable, and executed a nonrecourse promissory note, secured by the cattle, for $ 1,065,000. In 1971, there was no established market price in the United States for such cattle, but during that year, such cattle normally sold in England for less than $ 1,000 per animal. Held: 1. The purchase price paid by X for the cattle was at least 3…
1Opinion of the Court
Edward B. Hager and Jane E. Hager, Petitioners v. Commissioner of Internal Revenue, Respondent; Constantine L. Hampers and Lavonne J. Hampers, Petitioners v. Commissioner of Internal Revenue, Respondent
Hager v. Commissioner
Docket Nos. 11952-77, 283-78
United States Tax Court
76 T.C. 759; 1981 U.S. Tax Ct. LEXIS 128;
May 14, 1981, Filed
Decisions will be entered under Rule 155.
In 1971, Ps became limited partners of X. At the same time, X purchased 107 head of imported cattle from Y, a related entity, for $ 1,614,000. As consideration for the purchase, X paid $ 20,000 in cash, executed a short-term…
2Cases cited24 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Golanty v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
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