Bryant v. Commissioner
United States Tax Court
1. Held, petitioner is not entitled to a bad debt deduction for 1973. 2. Held,further, the entire gain realized by petitioner on the sale of a farm and improvements to Dr. Barnes in 1973 is taxable as long-term capital gain.
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1. Held, petitioner is not entitled to a bad debt deduction for 1973. 2. Held,further, the entire gain realized by petitioner on the sale of a farm and improvements to Dr. Barnes in 1973 is taxable as long-term capital gain. No gain was realized on the sale of sec. 1245 property. 3. Amount and character of gain realized by petitioners on sale of equipment at auction determined. 4. Held, petitioner is liable for the addition to tax imposed under sec. 6653(a), I.R.C. 1954, for each of the years 1972, 1973, and 1974. 5. Held, petitioner is liable for the addition to tax imposed under sec.…
1Opinion of the Court
OSCAR BRYANT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Bryant v. Commissioner
Docket No. 3727-79.
United States Tax Court
T.C. Memo 1982-169; 1982 Tax Ct. Memo LEXIS 577; 43 T.C.M. (CCH) 967; T.C.M. (RIA) 82169;
March 31, 1982.
1. Held, petitioner is not entitled to a bad debt deduction for 1973.
2. Held,further, the entire gain realized by petitioner on the sale of a farm and improvements to Dr. Barnes in 1973 is taxable as long-term capital gain. No gain was realized on the sale of sec. 1245 property.
3. Amount and character of gain realized by petitioners on sale of equipment at…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Bixby v. CommissionerUnited States Tax Court · 1972
- Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Dustin v. CommissionerUnited States Tax Court · 1969
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