Hurlburt v. Commissioner
United States Tax Court
Where a taxpayer, who reported his income on the cash receipts and disbursements basis, sold real estate and received a part of the consideration in cash and the purchaser contracted to make deferred payments in future years, held, such contractual obligations were not amounts realized by the taxpayer in the year of the sale.
1Opinion of the Court
OPINION.
Mulroney, Judge:
The Commissioner determined a deficiency in income tax in the amount of $4,555.07 for the calendar year 1947. The sole issue is whether certain contracts entered into by Coid Hurl-burt, decedent, in the sale of certain parcels óf real estate in 1947 were includible in income as amounts realized under section 111 (b) of the 1939 Internal Revenue Code.
All of the facts have been stipulated and they are herein incorporated by this reference.
The decedent, Coid Hurlburt, and his wife, Merle Hurlburt, filed a joint income tax return for the year 1947 with the then collector…
2Cases cited2 opinions
- Johnston v. CommissionerUnited States Tax Court · 1950
- Estate of Ennis v. CommissionerUnited States Tax Court · 1955
3Cited by20 opinions
- Western Oaks Bldg. Corp. v. CommissionerUnited States Tax Court · 1968
- Warren Jones Co. v. CommissionerUnited States Tax Court · 1973
- Yunker v. CommissionerUnited States Tax Court · 1956
- George L. Castner Co. v. CommissionerUnited States Tax Court · 1958
- Herbert Kaufman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1966
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