Young v. Commissioner
United States Tax Court
Ps, H and W, were divorced in 1988. Pursuant to their 1989 property settlement, H transferred to W his promissory note for $ 1,500,000. After H defaulted on the note, a State court entered judgment in favor of W. In 1992, as part of a settlement agreement relating to the judgment, H transferred property to W in exchange for the promissory note.
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Ps, H and W, were divorced in 1988. Pursuant to their 1989 property settlement, H transferred to W his promissory note for $ 1,500,000. After H defaulted on the note, a State court entered judgment in favor of W. In 1992, as part of a settlement agreement relating to the judgment, H transferred property to W in exchange for the promissory note. The transfer satisfied the principal, accrued interest, and legal and collection expenses due pursuant to the terms of the promissory note. 1. HELD: Sec. 1041 applies to the 1992 transfer of property, from H to W, that resolved a dispute that arose…
1Opinion of the Court
Foley, Judge:
Respondent determined the following deficiencies in, addition to, and penalty related to petitioners’ Federal income tax:
John B. Young and Martha H. Young, docket No. 20435-97:
Penalty Year Deficiency sec. 6662(a)
$636,856 $126,241 M CO CD to
98,716 19,685 Í — 1 CD CD CO
Louise F. Young, f.k.a. Louise Y. Ausman, and James R. Ausman, docket No. 21489-97:
Addition to tax Year Deficiency sec. 6651(a)(1)
1992 $212,888 $21,121
1993 609,319
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the…
2Cases cited8 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- O'Malley v. CommissionerUnited States Tax Court · 1988
- Daniel S. W. Kelly v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Kelly v. CommissionerUnited States Tax Court · 1955
3 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
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- Ray v. CIRCourt of Appeals for the Fifth Circuit · 2021
- Young v. Commissioner IRSCourt of Appeals for the Fourth Circuit · 2001
- Belot v. Comm'rUnited States Tax Court · 2016
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