Scheuber v. Commissioner
United States Tax Court
Held: That petitioners are not collaterally estopped from denying that certain properties were held primarily for sale to customers in the ordinary course of a trade or business when the prior litigation in this Court was concerned with separate transactions involving different properties and tax years. Held, further: That certain properties were held primarily for sale to customers in the ordinary course of a trade or business.
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Held: That petitioners are not collaterally estopped from denying that certain properties were held primarily for sale to customers in the ordinary course of a trade or business when the prior litigation in this Court was concerned with separate transactions involving different properties and tax years. Held, further: That certain properties were held primarily for sale to customers in the ordinary course of a trade or business. Held, further: That certain reinvestments of condemnation proceeds qualified for nonrecognition of gain treatment under section 1033, I.R.C. 1954.
1Opinion of the Court
William A. Scheuber and Hildegard Scheuber v. Commissioner.
Scheuber v. Commissioner
Docket No. 2231-63.
United States Tax Court
T.C. Memo 1966-107; 1966 Tax Ct. Memo LEXIS 173; 25 T.C.M. (CCH) 559; T.C.M. (RIA) 66107;
May 25, 1966
Held: That petitioners are not collaterally estopped from denying that certain properties were held primarily for sale to customers in the ordinary course of a trade or business when the prior litigation in this Court was concerned with separate transactions involving different properties and tax years.
Held, further: That certain properties were held primarily for sale…
2Cases cited19 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Malat v. RiddellSupreme Court of the United States · 1966
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
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