Hunter v. Commissioner
United States Tax Court
Petitioners owned ranches located within the boundaries of Grand Teton National Park. The National Park Service launched a program to acquire all such properties located within the park, and negotiated with petitioners to buy their land. Petitioners desired to continue to use their properties during their lives, and the Government, acting through the Superintendent of Grand Teton National Park, gave the petitioners the option to retain limited life estates in their ranches.
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Petitioners owned ranches located within the boundaries of Grand Teton National Park. The National Park Service launched a program to acquire all such properties located within the park, and negotiated with petitioners to buy their land. Petitioners desired to continue to use their properties during their lives, and the Government, acting through the Superintendent of Grand Teton National Park, gave the petitioners the option to retain limited life estates in their ranches. Petitioners then, in 1957, sold the properties to the United States, retaining limited life estates. Held: Although…
1Opinion of the Court
Hoyt, Judge:
The Commissioner determined a deficiency in the 1957 income tax of petitioner Eileen M. Hunter in the amount of $4,311.66 and a deficiency in the 1957 income tax of petitioners Frank H. and Inge F. Galey in the amount of $12,748.14. In an amendment to his answer in the Galey case respondent alleged that petitioners in that case had a corrected basis in their remainder interest of $22,737.58; this increased the deficiency to $14,150.37. These two cases were consolidated for trial, briefing, and opinion.
The questions for decision are:(1) Whether Code section 1033 providing for…
2Cases cited8 opinions
- Thomas v. PerkinsSupreme Court of the United States · 1937
- Welsh Homes, Incorporated, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1960
- Perkins v. ThomasCourt of Appeals for the Fifth Circuit · 1936
- Weish Homes, Inc. v. CommissionerUnited States Tax Court · 1959
- Columbia Oil & Gas Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1941
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Eller v. CommissionerUnited States Tax Court · 1981
- Lomas Santa Fe, Inc. v. CommissionerUnited States Tax Court · 1980
- Eller v. CommissionerUnited States Tax Court · 1981
- Giberson v. CommissionerUnited States Tax Court · 1982
- Hunter v. CommissionerUnited States Tax Court · 1965
1 more not listed; retrieve them via the Exa API.