Legal Opinion

King v. Commissioner

United States Tax Court

Decided November 17, 1981No. Docket No. 1273-79Published

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

J. Robert King, Jr., and Virginia S. King, Petitioners v. Commissioner of Internal Revenue, Respondent

King v. Commissioner

Docket No. 1273-79

United States Tax Court

77 T.C. 1113; 1981 U.S. Tax Ct. LEXIS 28;

November 17, 1981, Filed

Decision will be entered under Rule 155.

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…

2Cases cited15 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

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