Legal Opinion

Bankers Mortg. Co. v. Commissioner

United States Tax Court

Decided March 2, 1943No. Docket No. 106993Published

In 1937 petitioner had a transaction with the Humble Oil & Refining Co. by which it received from that company $ 300,000 in cash and executed to Humble its two nonnegotiable notes due on or before thirty years after date, and at the same time executed a deed of trust purporting to secure payment of these notes by an assignment to a trustee of certain oil and gas and sulphur interests and royalties, and on the same day, and as a part of the same transaction, petitioner and…

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In 1937 petitioner had a transaction with the Humble Oil & Refining Co. by which it received from that company $ 300,000 in cash and executed to Humble its two nonnegotiable notes due on or before thirty years after date, and at the same time executed a deed of trust purporting to secure payment of these notes by an assignment to a trustee of certain oil and gas and sulphur interests and royalties, and on the same day, and as a part of the same transaction, petitioner and Humble executed a contract modifying in certain important particulars the provisions of the notes and deed of trust. Held,…

1Opinion of the Court

Bankers Mortgage Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bankers Mortg. Co. v. Commissioner

Docket No. 106993

United States Tax Court

1 T.C. 698; 1943 U.S. Tax Ct. LEXIS 221;

March 2, 1943, Promulgated

Decision will be entered under Rule 50.

In 1937 petitioner had a transaction with the Humble Oil & Refining Co. by which it received from that company $ 300,000 in cash and executed to Humble its two nonnegotiable notes due on or before thirty years after date, and at the same time executed a deed of trust purporting to secure payment of these notes by an assignment to a…

2Cases cited1 opinion

  1. Bankers Mortg. Co. v. CommissionerUnited States Tax Court · 1943

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