Zappo v. Commissioner
United States Tax Court
Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasing shares of Company and lending money to Zappo and Murphy. Later, New Investors had a disagreement with Zappo and Murphy relating to Company and repayment of the loans.
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Zappo and Murphy formed Company to construct and sell townhouses. New Investors entered the venture by purchasing shares of Company and lending money to Zappo and Murphy. Later, New Investors had a disagreement with Zappo and Murphy relating to Company and repayment of the loans. The disagreement was resolved under a settlement agreement, whereby Zappo and Murphy transferred their Company shares to New Investors, and New Investors released Zappo and Murphy from their prior loan obligations. On the same date, Company sold incomplete townhouses to N.V.T.H. in exchange for cash and a contingent…
1Opinion of the Court
Shields, Judge:
Respondent determined a deficiency of $18,040.20 and an addition to tax under section 6653(b)1 of $9,020.10 in petitioners’ Federal income taxes for 1974. Due to concessions by the parties, the sole remaining issue is whether petitioners had taxable gain in 1974 resulting from a settlement agreement made between petitioner Angelo Zappo (Zappo). and certain of his creditors.
FINDINGS OF FACT
This case was submitted fully stipulated pursuant to Rule 122.2 The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Petitioners Angelo Zappo and…
2Cases cited29 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Eckert v. BurnetSupreme Court of the United States · 1931
- Helvering v. PriceSupreme Court of the United States · 1940
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
24 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Abramson v. CommissionerUnited States Tax Court · 1986
- Merkel v. CommissionerUnited States Tax Court · 1997
- Estate of Schneider v. CommissionerUnited States Tax Court · 1987
- Jelle v. CommissionerUnited States Tax Court · 2001
- Carolina, C. & O. R. Co. v. CommissionerUnited States Tax Court · 1984
12 more not listed; retrieve them via the Exa API.