Carp v. Commissioner
United States Board of Tax Appeals
1. TAXABLE TRANSACTION - ESCROW. - Where the petitioner in 1926 sold his stock in a corporation for $50,000 cash and $50,000 in notes payable over a period of 100 weeks, and the certificates of stock were placed in escrow until all the notes were paid, the transaction was completed and is taxable in 1926. Seletha O. Thompson,9 B.T.A. 1342, and John W. Sherwood,8 B.T.A. 103, followed. 2. REDUCTION OF CONSIDERATION. - Where petitioner in 1928 made a settlement with the…
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1. TAXABLE TRANSACTION - ESCROW. - Where the petitioner in 1926 sold his stock in a corporation for $50,000 cash and $50,000 in notes payable over a period of 100 weeks, and the certificates of stock were placed in escrow until all the notes were paid, the transaction was completed and is taxable in 1926. Seletha O. Thompson,9 B.T.A. 1342, and John W. Sherwood,8 B.T.A. 103, followed. 2. REDUCTION OF CONSIDERATION. - Where petitioner in 1928 made a settlement with the purchasers of the stock by which he reduced the selling price of the stock by $12,814.53, the reduction does not affect the tax…
1Opinion of the Court
JACOB CARP, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Carp v. Commissioner
Docket No. 52794.
United States Board of Tax Appeals
31 B.T.A. 541; 1934 BTA LEXIS 1070;
November 8, 1934, Promulgated
1. TAXABLE TRANSACTION - ESCROW. - Where the petitioner in 1926 sold his stock in a corporation for $50,000 cash and $50,000 in notes payable over a period of 100 weeks, and the certificates of stock were placed in escrow until all the notes were paid, the transaction was completed and is taxable in 1926. Seletha O. Thompson,9 B.T.A. 1342, and John W. Sherwood,8 B.T.A. 103, followed.
2.…
2Cases cited2 opinions
- Thompson v. CommissionerUnited States Board of Tax Appeals · 1928
- Carp v. CommissionerUnited States Board of Tax Appeals · 1934