Legal Opinion

King v. Commissioner

United States Tax Court

Decided November 17, 1981No. Docket No. 1273-79PublishedCited by 5 opinions

Held, the interest received on warrants obtained as part of the consideration for land sold to the Trinity River Authority under a threat of condemnation is not excludable from gross income under sec. 103(a)(1), I.R.C. 1954. Drew v. United States, 551 F.2d 85 (5th Cir. 1977), followed.

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Held, the interest received on warrants obtained as part of the consideration for land sold to the Trinity River Authority under a threat of condemnation is not excludable from gross income under sec. 103(a)(1), I.R.C. 1954. Drew v. United States, 551 F.2d 85 (5th Cir. 1977), followed. Held, further, interest received on warrants obtained as part of the consideration for land sold to the Trinity River Authority in a voluntary transaction is excludable from gross income under sec. 103(a)(1), I.R.C. 1954.

1Opinion of the Court

Featherston, Judge:

Respondent determined the following deficiencies in petitioners’ Federal income taxes:

Year Amount

1971....$17,492

1972. 4,941

1973. 7,791

1974. 4,108

The issue for decision is whether the interest, or any portion thereof, received by petitioner Virginia S. King on warrants issued to her by the Trinity River Authority is excludable from income for the years in controversy under section 103(a)(1).1

FINDINGS OF FACT2

Petitioners J. Robert King, Jr., and Virginia S. King, husband and wife, were legal residents of Texas when they filed their petition. They filed their joint Federal…

2Cases cited14 opinions

  1. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  2. Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
  3. United States Trust Co. of New York v. AndersonCourt of Appeals for the Second Circuit · 1933
  4. Holley v. United StatesCourt of Appeals for the Sixth Circuit · 1942
  5. Newlin Machinery Corp. v. CommissionerUnited States Tax Court · 1957

9 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. DeNaples v. Comm'rUnited States Tax Court · 2011
  2. Stewart v. CommissionerUnited States Tax Court · 1982
  3. Barrow v. CommissionerUnited States Tax Court · 1983
  4. King v. CommissionerUnited States Tax Court · 1981
  5. Thompson v. CommissionerUnited States Tax Court · 1983

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