Legal Opinion

Greenspun v. Commissioner

United States Tax Court

Decided August 28, 1979No. Docket No. 4602-73PublishedCited by 35 opinions

In late 1966, Howard R. Hughes (Hughes) moved to Las Vegas, Nev., where he resided until sometime in 1970. Shortly after his arrival, Hughes undertook to make substantial investments and acquisitions in and around the Las Vegas area. To offset anticipated opposition to many of his acquisitions, Hughes sought to acquire a large part of the newspaper, radio, and television interests in the Las Vegas area.

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In late 1966, Howard R. Hughes (Hughes) moved to Las Vegas, Nev., where he resided until sometime in 1970. Shortly after his arrival, Hughes undertook to make substantial investments and acquisitions in and around the Las Vegas area. To offset anticipated opposition to many of his acquisitions, Hughes sought to acquire a large part of the newspaper, radio, and television interests in the Las Vegas area. His intentions in doing so were to acquire the means through which he could create a favorable public image of himself by manipulation of a friendly press. Petitioner at this time was the…

1Opinion of the Court

OPINION

Fay, Judge:

Respondent determined deficiencies in petitioners’ Federal income tax as follows:

Year Deficiency

1967 $469,613.77

1969 1,157,956.19

We have been asked to decide the extent to which, if any, petitioners realized income subject to taxation upon their receipt of a loan in the amount of $4 million at 3-percent interest for a period of years.

All of the facts have been stipulated and are so found.

At the time of filing their petition herein, Herman M. and Barbara J. Greenspun, husband and wife, resided in Las Vegas, Nev.

Since 1950, petitioner Herman M. Greenspun (hereinafter…

2Cases cited29 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. Commissioner v. SmithSupreme Court of the United States · 1945
  4. Palmer v. CommissionerSupreme Court of the United States · 1937
  5. Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962

24 more not listed; retrieve them via the Exa API.

3Cited by35 opinions

  1. Huff v. CommissionerUnited States Tax Court · 1983
  2. La Fargue v. CommissionerUnited States Tax Court · 1979
  3. United States v. Jack E. White, United States of America v. Gene KuykendallCourt of Appeals for the Eighth Circuit · 1982
  4. Zager v. CommissionerUnited States Tax Court · 1979
  5. Colin F. And Eleanor M. Beaton v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1981

30 more not listed; retrieve them via the Exa API.

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