Shannon v. Commissioner
United States Tax Court
1. In 1949, the executor-trustees under the will of Mattie Hedgecoke, who held title to an undivided one-fourth interest in a ranch and other lands, joined with others referred to below holding title to the remaining interests in said properties in conveying the entire interest therein to M M Cattle Co., a newly organized corporation, the consideration therefor being $ 2,500,000, of which $ 50,000 was paid by the corporation in cash, the balance of $ 2,450,000 being payable…
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1. In 1949, the executor-trustees under the will of Mattie Hedgecoke, who held title to an undivided one-fourth interest in a ranch and other lands, joined with others referred to below holding title to the remaining interests in said properties in conveying the entire interest therein to M M Cattle Co., a newly organized corporation, the consideration therefor being $ 2,500,000, of which $ 50,000 was paid by the corporation in cash, the balance of $ 2,450,000 being payable in 49 equal annual installments, the deferred payments being evidenced by a vendor's lien installment note. 4,446 shares…
1Opinion of the Court
FisheR, Judge:
This consolidated proceeding involves deficiencies in income tax determined against petitioners as follows:
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On October 12, 1956, petitioners in all of the above dockets, by amended petitions, struck out paragraph 3 of their original petitions and substituted a new paragraph 3 claiming an overpayment in the amount of $765.10 for the taxable year 1950 as to all docket numbers except No. 53043, in which an overpayment in a like amount was claimed for 1949. The amended petition in Estate of E. L. Morris, deceased, and Garland H. Morris (now Garland H. King), Docket No.…
2Cases cited26 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Dobkin v. CommissionerUnited States Tax Court · 1950
21 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Curry v. CommissionerUnited States Tax Court · 1965
- Yamamoto v. CommissionerUnited States Tax Court · 1980
- J. I. Morgan, Inc. v. CommissionerUnited States Tax Court · 1958
- Dixie Portland Flour Co. v. CommissionerUnited States Tax Court · 1958
- State-Adams Corp. v. CommissionerUnited States Tax Court · 1959
13 more not listed; retrieve them via the Exa API.