Farha v. Commissioner
United States Tax Court
Petitioners were shareholders of a corporation active in the production and sale of certain processed foods. They also were partners in a partnership which owned the land, the building, and certain other assets used by the corporation. On Aug. 19, 1967, petitioners agreed to sell substantially all of the partnership to Hormel.
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Petitioners were shareholders of a corporation active in the production and sale of certain processed foods. They also were partners in a partnership which owned the land, the building, and certain other assets used by the corporation. On Aug. 19, 1967, petitioners agreed to sell substantially all of the partnership to Hormel. On the same day in a separate agreement with Hormel, petitioners purportedly sold 80 percent of their stock in the corporation and Hormel purportedly agreed to effect, sometime within the following month, the redemption of petitioners' remaining 20 percent of stock.…
1Opinion of the Court
OPINION
FORRESTER, Judge:
For the calendar year 1967 respondent has determined deficiencies in petitioners’ income taxes of $24,282.31, $5,379.65, $5,475.06, and $21,900.23 in docket Nos. 2358-70,2359-70,2360-70, and 2361-70, respectively. Petitioners have conceded all but one of the originally disputed issues. Tlie only question for our decision is whether petitioners are entitled to installment sale treatment under section 453 2 with respect to the gain they derived from their sale of the outstanding stock of their closely held corporation.
All of the facts have been stipulated. The…
2Cases cited15 opinions
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
- C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
10 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Pritchett v. CommissionerUnited States Tax Court · 1974
- Monson v. CommissionerUnited States Tax Court · 1982
- Glisson v. CommissionerUnited States Tax Court · 1981
- Farha v. CommissionerUnited States Tax Court · 1972
- Monson v. CommissionerUnited States Tax Court · 1982
2 more not listed; retrieve them via the Exa API.