Legg v. Commissioner
United States Tax Court
Petitioners sold an apple orchard electing to report the gain on the installment method. The contract provided for payment of interest which aggregated $ 6,000 per year during petitioners' lives; principal payable on their death. Contemporaneous with the sale, petitioners conveyed the installment sales contract to an irrevocable trust retaining the right to receive an annual payment of $ 6,000; the corpus payable on their death to a charitable foundation.
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Petitioners sold an apple orchard electing to report the gain on the installment method. The contract provided for payment of interest which aggregated $ 6,000 per year during petitioners' lives; principal payable on their death. Contemporaneous with the sale, petitioners conveyed the installment sales contract to an irrevocable trust retaining the right to receive an annual payment of $ 6,000; the corpus payable on their death to a charitable foundation. Held, (1) the transfer of the installment obligation to the trust was a disposition of the principal interest within the meaning of sec.…
1Opinion of the Court
A. W. Legg and Williamena Legg, Petitioners v. Commissioner of Internal Revenue, Respondent
Legg v. Commissioner
Docket No. 2407-69
United States Tax Court
57 T.C. 164; 1971 U.S. Tax Ct. LEXIS 32;
November 1, 1971, Filed
Decision will be entered under Rule 50.
Petitioners sold an apple orchard electing to report the gain on the installment method. The contract provided for payment of interest which aggregated $ 6,000 per year during petitioners' lives; principal payable on their death. Contemporaneous with the sale, petitioners conveyed the installment sales contract to an irrevocable trust…
2Cases cited6 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- United States v. FlannerySupreme Court of the United States · 1925
- Legg v. CommissionerUnited States Tax Court · 1971
- New York Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Milby & Dow Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1931
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