Finch v. Commissioner
United States Tax Court
Decedent died within 3 years from the date of a conditional sales contract to purchase a business. After decedent died, the seller exercised his election under the contract. He elected to repossess the business rather than require decedent's heirs to continue to make payments under the contract. There was a loss of decedent's investment.
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Decedent died within 3 years from the date of a conditional sales contract to purchase a business. After decedent died, the seller exercised his election under the contract. He elected to repossess the business rather than require decedent's heirs to continue to make payments under the contract. There was a loss of decedent's investment. Held: The business did not revert to the seller immediately upon or as of decedent's death; the reversion was after his death; the loss was not sustained during the taxable period which ended with his death. Respondent's disallowance of loss deduction is…
1Opinion of the Court
Estate of Ura M. Finch, Deceased, Alice E. Finch, Administratrix, and Alice E. Finch, Individually, Petitioners, v. Commissioner of Internal Revenue, Respondent
Finch v. Commissioner
Docket No. 47876
United States Tax Court
24 T.C. 403; 1955 U.S. Tax Ct. LEXIS 170;
June 15, 1955, Filed
Decision will be entered for the respondent.
Decedent died within 3 years from the date of a conditional sales contract to purchase a business. After decedent died, the seller exercised his election under the contract. He elected to repossess the business rather than require decedent's heirs to continue to make…
2Cases cited3 opinions
- Howe v. CommissionerUnited States Tax Court · 1951
- National Metropolitan Bank of Washington v. United StatesUnited States Court of Claims · 1953
- Finch v. CommissionerUnited States Tax Court · 1955