Edwards v. Commissioner
United States Tax Court
In 1962, petitioners purchased stock and notes of a corporation for $ 75,000. The purchase contract allocated $ 5,000 to the stock and $ 70,000 to the notes. Held, amounts received by petitioners from the corporation on the principal of the notes did not constitute amounts received in exchange for such notes under sec. 1232(a), I.R.C. 1954.
1Opinion of the Court
R. M. Edwards and Dorothy Edwards, Petitioners v. Commissioner of Internal Revenue, Respondent; Loyd W. Disler and Joy Disler, Petitioners v. Commissioner of Internal Revenue, Respondent
Edwards v. Commissioner
Docket Nos. 2369-66, 2388-66
United States Tax Court
50 T.C. 220; 1968 U.S. Tax Ct. LEXIS 134;
May 2, 1968, Filed
Decisions will be entered under Rule 50.
In 1962, petitioners purchased stock and notes of a corporation for $ 75,000. The purchase contract allocated $ 5,000 to the stock and $ 70,000 to the notes. Held, amounts received by petitioners from the corporation on the principal of the…
Also in this document: Concurrence; Dissent.
2Cases cited27 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
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