Hedrick v. Commissioner
United States Tax Court
A decedent had disposed of property pursuant to an arrangement which was adjudicated to be a long-term installment sales contract bearing an interest rate of 7 percent for purposes of computing the amount of interest received in each installment. Petitioner inherited the decedent's rights under the installment sales contract and received the installments paid thereafter.
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A decedent had disposed of property pursuant to an arrangement which was adjudicated to be a long-term installment sales contract bearing an interest rate of 7 percent for purposes of computing the amount of interest received in each installment. Petitioner inherited the decedent's rights under the installment sales contract and received the installments paid thereafter. Held, that amounts received by petitioner pursuant to the installment sales contract were income in respect of a decedent under sec. 691(a), I.R.C. 1954, and were reportable by petitioner in the same manner that the decedent…
1Opinion of the Court
OPINION
Raum, Judge:
At the root of this case lies the question whether the payments under the contract of sale, which petitioner received by operation of his deceased wife’s will, constitute income in respect of a decedent subject to taxation as provided in section 691, I.R.C. 1954. Pertinent portions of section 691 are set forth in the margin.2
The generally operative language of these provisions is contained in (a)(1) wherein it is provided that “all items of gross income in respect of a decedent * * * shall be included in the gross income, for the taxable year when received.” Further, (a)(3)…
2Cases cited11 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Dixon v. United StatesSupreme Court of the United States · 1965
- Emma R. Dorl v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1974
- Dorl v. CommissionerUnited States Tax Court · 1972
6 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Abeles v. CommissionerUnited States Tax Court · 1988
- Estate of Robinson v. CommissionerUnited States Tax Court · 1977
- Boomershine v. CommissionerUnited States Tax Court · 1987
- Buehler v. CommissionerUnited States Tax Court · 1987
- Barnes v. Comm'rUnited States Tax Court · 2016
14 more not listed; retrieve them via the Exa API.