Freeman v. Commissioner
United States Tax Court
Evidence of indebtedness received by petitioners in 1956 as part of selling price of stock was not "evidence of indebtedness of purchaser" as provided by section 453(b)(2)(A)(ii) of the 1954 Code so that payments to them in 1956 exceeded 30 percent of the selling price. Held, petitioners are not entitled to report sale of stock on installment method as provided by section 453.
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in the 1956 income tax liability of petitioners in the following amounts:
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The sole issue for determination is whether the petitioners are entitled to report the sale of their stock in the Springfield Baptist Hospital Association on the installment method of accounting as provided in section 453 of the 1954 Code.
findings of fact.
Some of the facts are stipulated and are hereby found as stipulated.
The petitioner in Docket Nos. 84016 and 84018 is a fiduciary incorporated under the laws of the State of Missouri, with the principal place…
2Cases cited5 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Caldwell v. United StatesCourt of Appeals for the Third Circuit · 1940
- Elmore v. CommissionerUnited States Board of Tax Appeals · 1929
- Georgia-Florida Land Co. v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by15 opinions
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Gus Russell, Inc. v. CommissionerUnited States Tax Court · 1961
- Cisler v. CommissionerUnited States Tax Court · 1962
- Monson v. CommissionerUnited States Tax Court · 1982
- Reitz v. CommissionerUnited States Tax Court · 1974
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