Dudden v. Commissioner
United States Tax Court
Petitioners acquired substantial incidents of beneficial ownership in gilts they received from their closely held farm corporation when the animals weighed 220 pounds. Held, the acquired gilts represent rental income received in kind. Held, further, petitioners must recognize rental income on their transfer of the gilts to their leased breeding herd.
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Petitioners acquired substantial incidents of beneficial ownership in gilts they received from their closely held farm corporation when the animals weighed 220 pounds. Held, the acquired gilts represent rental income received in kind. Held, further, petitioners must recognize rental income on their transfer of the gilts to their leased breeding herd. Held, further, the amount of rental income recognized per gilt acquired is equal to the value of 220-pound gilt on the date petitioners acquired beneficial ownership in the animals.
1Opinion of the Court
HAMBLEN, Judge:
For petitioners’ taxable years ended December 31, 1980, and December 31, 1981, respondent determined respective deficiencies in petitioners’ Federal income taxes of $3,743 and $1,871. After concessions,1 the primary issue for determination is whether petitioners were correct in not reporting any rental income from their acquisition of livestock which they designated as replacements or additions to their breeding herds.
FINDINGS OF FACT
Some of the facts are stipulated and found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference.
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2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burnet v. HarmelSupreme Court of the United States · 1932
- Poe v. SeabornSupreme Court of the United States · 1930
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Yelencsics v. CommissionerUnited States Tax Court · 1980
18 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Dudden v. CommissionerUnited States Tax Court · 1988