Sholund v. Commissioner
United States Tax Court
1. Petitioners retained the services of Realty to facilitate the sale of the Evergreen Ballroom. Realty found a purchaser and the sale was consummated. The purchase price was $ 55,000, payable $ 10,000 down and $ 300 per month with interest at 6 percent on deferred monthly balances. Petitioners agreed with Realty to defer the payment of its commission.
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1. Petitioners retained the services of Realty to facilitate the sale of the Evergreen Ballroom. Realty found a purchaser and the sale was consummated. The purchase price was $ 55,000, payable $ 10,000 down and $ 300 per month with interest at 6 percent on deferred monthly balances. Petitioners agreed with Realty to defer the payment of its commission. Petitioners authorized the bank on receipt of payments from the purchaser to remit them directly to Realty until the commission was paid. Held, petitioners must report their allocable portions of gain and interest income resulting from each…
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in the Federal income taxes of petitioners as follows:
Docket No. Petitioners Year Amount
2350-67 Konald W. and Elizabeth G. Sholund-1964 1965 $426.94 251.73
2351-67 Elmer E. and Mary O. Erickson. 1964 1965 366.63 293.53
Various adjustments made in the statutory notice of deficiency in each docket have been stipulated to by the parties. Because the petitioners in docket No. 2350-67 did not contest a portion of one of the adjustments relating to 1964, we hold that portion to be conceded. The issues remaining for determination are (1) whether…
2Cases cited12 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Henry v. CommissionerUnited States Tax Court · 1961
- Boehm v. CommissionerUnited States Board of Tax Appeals · 1937
- Larrabee v. CommissionerUnited States Tax Court · 1960
7 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Carey v. CommissionerUnited States Tax Court · 1971
- Martino v. CommissionerUnited States Tax Court · 1974
- Maness v. CommissionerUnited States Tax Court · 1970
- Finney v. CommissionerUnited States Tax Court · 1980
- Holland v. CommissionerUnited States Tax Court · 1985
8 more not listed; retrieve them via the Exa API.