Legal Opinion

Shannon v. Commissioner

United States Tax Court

Decided January 28, 1958No. Docket Nos. 53038, 53039, 53040, 53041, 53042, 53043, 53044Published

1. In 1949, the executor-trustees under the will of Mattie Hedgecoke, who held title to an undivided one-fourth interest in a ranch and other lands, joined with others referred to below holding title to the remaining interests in said properties in conveying the entire interest therein to M M Cattle Co., a newly organized corporation, the consideration therefor being $ 2,500,000, of which $ 50,000 was paid by the corporation in cash, the balance of $ 2,450,000 being payable…

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1. In 1949, the executor-trustees under the will of Mattie Hedgecoke, who held title to an undivided one-fourth interest in a ranch and other lands, joined with others referred to below holding title to the remaining interests in said properties in conveying the entire interest therein to M M Cattle Co., a newly organized corporation, the consideration therefor being $ 2,500,000, of which $ 50,000 was paid by the corporation in cash, the balance of $ 2,450,000 being payable in 49 equal annual installments, the deferred payments being evidenced by a vendor's lien installment note. 4,446 shares…

1Opinion of the Court

Harry F. Shannon, Dixie Shannon (Formerly Dixie H. Smith), et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Shannon v. Commissioner

Docket Nos. 53038, 53039, 53040, 53041, 53042, 53043, 53044

United States Tax Court

29 T.C. 702; 1958 U.S. Tax Ct. LEXIS 271; 29 T.C. No. 80;

January 28, 1958, Filed

Decisions will be entered under Rule 50.

1. In 1949, the executor-trustees under the will of Mattie Hedgecoke, who held title to an undivided one-fourth interest in a ranch and other lands, joined with others referred to below holding title to the remaining interests in said properties…

2Cases cited28 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Blair v. CommissionerSupreme Court of the United States · 1937
  3. Freuler v. HelveringSupreme Court of the United States · 1934
  4. LeTulle v. ScofieldSupreme Court of the United States · 1940
  5. Dobkin v. CommissionerUnited States Tax Court · 1950

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