King v. Commissioner
United States Tax Court
In anticipation of divorce, petitioner and his then wife entered into an agreement, subsequently incorporated in a divorce decree, whereby, inter alia, petitioner obligated himself to convey to his wife a life estate in his undivided one-half interest in a ranch, with remainder to their children, and to satisfy an existing mortgage encumbrance thereon.
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In anticipation of divorce, petitioner and his then wife entered into an agreement, subsequently incorporated in a divorce decree, whereby, inter alia, petitioner obligated himself to convey to his wife a life estate in his undivided one-half interest in a ranch, with remainder to their children, and to satisfy an existing mortgage encumbrance thereon. Petitioner's then wife agreed to accept benefits flowing to her under the agreement in full satisfaction of her rights to alimony and support and fully released petitioner from any further obligations toward her, with exceptions not here…
1Opinion of the Court
Forrester, Judge:
The Commissioner has determined a deficiency in the income tax of petitioner E. Eugene King for 1952 and additions thereto under sections 294 (d) (1) (A) and 294 (d) (2) of the Internal Revenue Code of 1939, and deficiencies in the income tax of both petitioners for 1953 and 1954, as follows:
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The issues to be decided are as follows:
1. Did respondent err in determining that petitioner E. Eugene King realized taxable gain in 1952 as the result of the transfer by him of his interest in a certain ranch property ?
2. If respondent did not so err, the following…
2Cases cited12 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Smith v. CommissionerUnited States Tax Court · 1953
- Hartley v. CommissionerUnited States Tax Court · 1954
- Feves v. FevesOregon Supreme Court · 1953
- Commissioner of Internal Revenue v. MestaCourt of Appeals for the Third Circuit · 1941
7 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- United States v. DavisSupreme Court of the United States · 1962
- Robertson v. CommissionerUnited States Tax Court · 1971
- A. Finkl & Sons Co. v. CommissionerUnited States Tax Court · 1962
- Wallace v. United StatesDistrict Court, S.D. Iowa · 1970
- Close v. CommissionerUnited States Tax Court · 1959
2 more not listed; retrieve them via the Exa API.