Bassett v. Commissioner
United States Tax Court
Held, amounts received as royalties by petitioners, as donees of a gift of a royalty right from their son, as donor, where he on July 17, 1936, and December 4, 1937, had exchanged stock for original royalty interest which was held by a corporation, such exchange being in partial liquidation of the corporation, constitute ordinary income under sections 22(a), I.R.C. 1939, and 61(a), I.R.C. 1954.
1Opinion of the Court
Rex Earl Bassett, Sr., and Dot Bassett, Petitioners, v. Commissioner of Internal Revenue, Respondent
Bassett v. Commissioner
Docket No. 72580
United States Tax Court
36 T.C. 244; 1961 U.S. Tax Ct. LEXIS 155;
May 11, 1961, Filed
Decision will be entered for the respondent.
Held, amounts received as royalties by petitioners, as donees of a gift of a royalty right from their son, as donor, where he on July 17, 1936, and December 4, 1937, had exchanged stock for original royalty interest which was held by a corporation, such exchange being in partial liquidation of the corporation, constitute ordinary…
2Cases cited11 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Commissioner of Internal Revenue v. CarterCourt of Appeals for the Second Circuit · 1948
- Commissioner of Internal Revenue v. HopkinsonCourt of Appeals for the Second Circuit · 1942
- Carter v. CommissionerUnited States Tax Court · 1947
- Westover v. SmithCourt of Appeals for the Ninth Circuit · 1949
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