Vaughn v. Commissioner
United States Tax Court
Petitioner-husband's corporation owned a large portion of an apartment complex, as well as some other assets. Petitioners were the sole partners in a partnership that owned the remainder of the apartment complex. Petitioners sold their partnership interests, and petitioner-husband sold all the stock of his corporation, to petitioner-wife's son under installment contracts.
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Petitioner-husband's corporation owned a large portion of an apartment complex, as well as some other assets. Petitioners were the sole partners in a partnership that owned the remainder of the apartment complex. Petitioners sold their partnership interests, and petitioner-husband sold all the stock of his corporation, to petitioner-wife's son under installment contracts. The contract for the sale of the stock included an escrow agreement under which the son was required to place any proceeds from the resale of the assets of the corporation into an escrow account. The escrow agreement did not…
1Opinion of the Court
Chabot, Judge:
Respondent determined a deficiency in Federal individual income tax against petitioners for 1973 in the amount of $289,338, and an addition to tax under section 6653(a)1 (negligence, etc.) in the amount of $14,467. After concessions,2 the issues for decision are (1) whether the sales of an apartment complex and stock by petitioners to petitioner-wife’s son were bona fide transactions entitled to recognition for Federal income tax purposes, and (2) whether petitioners are entitled to report these sales using the installment method of reporting income under section 453.
FINDINGS OF…
2Cases cited32 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
27 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Vaughn v. CommissionerUnited States Tax Court · 1986
- Gordon v. CommissionerUnited States Tax Court · 1985
- Sainte Claire Corp. v. CommissionerUnited States Tax Court · 1997
- CGF Indus., Inc. v. CommissionerUnited States Tax Court · 1999
- Failla v. CommissionerUnited States Tax Court · 1986
5 more not listed; retrieve them via the Exa API.