Legal Opinion

Independent Gravel Co. v. Commissioner

United States Tax Court

Decided June 30, 1971No. Docket No. 4988-69Published

The City of Joplin, Mo., issued special tax bills to petitioner in payment for street and sewer improvements which petitioner performed under contracts with the City. These bills were assessed against landowners whose properties were benefited by the improvements and became liens against the properties so benefited. Payment of principal and interest on the bills could be made by the landowner directly to petitioner or could be made to the City which would then forward it.

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The City of Joplin, Mo., issued special tax bills to petitioner in payment for street and sewer improvements which petitioner performed under contracts with the City. These bills were assessed against landowners whose properties were benefited by the improvements and became liens against the properties so benefited. Payment of principal and interest on the bills could be made by the landowner directly to petitioner or could be made to the City which would then forward it. In fact, payment was made directly to petitioner. Held, the special tax bills are governmental obligations and the…

1Opinion of the Court

Independent Gravel Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Independent Gravel Co. v. Commissioner

Docket No. 4988-69

United States Tax Court

56 T.C. 698; 1971 U.S. Tax Ct. LEXIS 105;

June 30, 1971, Filed

Decision will be entered for the petitioner.

The City of Joplin, Mo., issued special tax bills to petitioner in payment for street and sewer improvements which petitioner performed under contracts with the City. These bills were assessed against landowners whose properties were benefited by the improvements and became liens against the properties so benefited. Payment of…

2Cases cited15 opinions

  1. Commissioner of Internal Revenue v. White's EstateCourt of Appeals for the Second Circuit · 1944
  2. Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1940
  3. Commissioner of Internal Revenue v. PontarelliCourt of Appeals for the Seventh Circuit · 1938
  4. Pontarelli v. CommissionerUnited States Board of Tax Appeals · 1937
  5. Riverview State Bank v. CommissionerUnited States Tax Court · 1943

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