Legal Opinion

Baumgart v. Commissioner

United States Tax Court

Decided December 12, 1983No. Docket No. 14440-80UnpublishedCited by 2 opinions

Held: (1) Receipt of income from sale of railroad cars is ordinary income. (2) Petitioner has met his burden of proof with respect to $20,000 deducted as commission expense in 1976.

1Opinion of the Court

STEPHEN W. BAUMGART AND MARGARET G. BAUMGART, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Baumgart v. Commissioner

Docket No. 14440-80.

United States Tax Court

T.C. Memo 1983-738; 1983 Tax Ct. Memo LEXIS 48; 47 T.C.M. (CCH) 592; T.C.M. (RIA) 83738;

December 12, 1983.

Held:(1) Receipt of income from sale of railroad cars is ordinary income.(2) Petitioner has met his burden of proof with respect to $20,000 deducted as commission expense in 1976.

Douglas E. McKinley, for the petitioners.

Warren P. Simonsen, for the respondent.

WHITAKER

MEMORANDUM FINDINGS OF FACT AND OPINION

WHITAKER,…

2Cases cited28 opinions

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  3. Malat v. RiddellSupreme Court of the United States · 1966
  4. Brannen v. CommissionerUnited States Tax Court · 1982
  5. United States v. BasyeSupreme Court of the United States · 1973

23 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Pleasant Summit Land Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1988
  2. Pleasant Summit Land Corporation, in 88-1373 v. Commissioner of Internal Revenue. George Prussin and Sharon Prussin, in 88-1377 v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1988

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