Ferguson v. Commissioner
United States Tax Court
Petitioner owned an automobile dealership business and all of the stock of a corporation which owned three parcels of real estate. The automobile business was conducted in one of the buildings owned by the real estate corporation.
Read the full summary
Petitioner owned an automobile dealership business and all of the stock of a corporation which owned three parcels of real estate. The automobile business was conducted in one of the buildings owned by the real estate corporation. In 1955 petitioner sold his automobile business to a corporation (owned by unrelated persons), referred to as Enterprises, under an arrangement whereby a portion of the gross sales of the business was to be paid by Enterprises into a so-called experimental department, the funds to be used "for experimental purposes." Petitioner had complete control over the…
1Opinion of the Court
Hoyt, Judge:
Respondent determined an income tax deficiency against petitioner, Joseph B. Ferguson, for the year 1959 in the amount of $1,191.52. In various amendments to his answer filed herein, respondent asserted certain increased deficiencies totaling in excess of $310,000.
After various concessions by respondent at trial and on brief, the only questions remaining for decision are: (1) Whether certain payments totaling $132,592 made by Fergus Imported Cars, Inc., in 1959 represented taxable income to petitioner, and (2) whether interest income earned in 1959 by funds on deposit in a certain…
2Cases cited11 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. WheelerSupreme Court of the United States · 1945
- United Mercantile Agencies, Inc. v. CommissionerUnited States Tax Court · 1955
- F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Hadden v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Mazzocchi Bus Co. v. CommissionerUnited States Tax Court · 1993
- Webb v. CommissionerUnited States Tax Court · 1977
- MANNING v. COMMISSIONERUnited States Tax Court · 1993
- Arenstein v. CommissionerUnited States Tax Court · 1993
- Ferguson v. CommissionerUnited States Tax Court · 1966
2 more not listed; retrieve them via the Exa API.