Estate of Bowers v. Commissioner
United States Tax Court
T entered into an agreement of Apr. 28, 1982, to sell his Federal oil and gas lease to AQ Co. (AQ) for $ 2 million, which paid $ 400,000 earnest money therefor in May 1982. On some undisclosed date prior to July 1982, Browne Land Trust contracted to purchase a farm and related Federal Land Bank stock from an undisclosed seller for $ 877,000. The trust had no connection either with T or with AQ.
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T entered into an agreement of Apr. 28, 1982, to sell his Federal oil and gas lease to AQ Co. (AQ) for $ 2 million, which paid $ 400,000 earnest money therefor in May 1982. On some undisclosed date prior to July 1982, Browne Land Trust contracted to purchase a farm and related Federal Land Bank stock from an undisclosed seller for $ 877,000. The trust had no connection either with T or with AQ. The trust agreed on July 6, 1982, to transfer its interest in the farm to T for an additional $ 200,000. On July 7, 1982, the trust purchased the farm and stock, making payment therefor in part with…
1Opinion of the Court
Estate of Alexander S. Bowers, Deceased, Robert M. Musselman, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Bowers v. Commissioner
Docket No. 37702-87
United States Tax Court
94 T.C. 582; 1990 U.S. Tax Ct. LEXIS 40; 94 T.C. No. 34;
April 16, 1990April 16, 1990, Filed
Decision to be entered under Rule 155.
T entered into an agreement of Apr. 28, 1982, to sell his Federal oil and gas lease to AQ Co. (AQ) for $ 2 million, which paid $ 400,000 earnest money therefor in May 1982. On some undisclosed date prior to July 1982, Browne Land Trust contracted to purchase a farm…
2Cases cited26 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Bank of Commerce v. Tennessee Ex Rel. MemphisSupreme Court of the United States · 1896
- June Pinson Carlton and Charles T. Carlton, as Administrators of the Estate of Thad H. Carlton, and June Carlton v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Biggs v. CommissionerUnited States Tax Court · 1978
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