Dudden v. Commissioner
United States Tax Court
Petitioners acquired substantial incidents of beneficial ownership in gilts they received from their closely held farm corporation when the animals weighed 220 pounds. Held, the acquired gilts represent rental income received in kind. Held, further, petitioners must recognize rental income on their transfer of the gilts to their leased breeding herd.
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Petitioners acquired substantial incidents of beneficial ownership in gilts they received from their closely held farm corporation when the animals weighed 220 pounds. Held, the acquired gilts represent rental income received in kind. Held, further, petitioners must recognize rental income on their transfer of the gilts to their leased breeding herd. Held, further, the amount of rental income recognized per gilt acquired is equal to the value of 220-pound gilt on the date petitioners acquired beneficial ownership in the animals.
1Opinion of the Court
Roger P. and Marcia Dudden, Petitioners v. Commissioner of Internal Revenue, Respondent
Dudden v. Commissioner
Docket No. 8463-84
United States Tax Court
91 T.C. 642; 1988 U.S. Tax Ct. LEXIS 119; 91 T.C. No. 40;
September 14, 1988; As amended September 15, 1988 September 14, 1988, Filed
Decision will be entered under Rule 155.
Petitioners acquired substantial incidents of beneficial ownership in gilts they received from their closely held farm corporation when the animals weighed 220 pounds. Held, the acquired gilts represent rental income received in kind. Held, further, petitioners must recognize…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Yelencsics v. CommissionerUnited States Tax Court · 1980
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