Legal Opinion

Bellamy v. Commissioner

United States Tax Court

Decided January 27, 1965No. Docket No. 989-63Published

Held, that an amount received by the petitioner did not represent proceeds from the sale of a capital asset, and that such amount is taxable as ordinary income.

1Opinion of the Court

Ralph Bellamy and Alice Bellamy, Petitioners, v. Commissioner of Internal Revenue, Respondent

Bellamy v. Commissioner

Docket No. 989-63

United States Tax Court

43 T.C. 487; 1965 U.S. Tax Ct. LEXIS 138;

January 27, 1965, Filed January 27, 1965, Filed

Decision will be entered under Rule 50.

Held, that an amount received by the petitioner did not represent proceeds from the sale of a capital asset, and that such amount is taxable as ordinary income.

Dana Latham, Henry C. Diehl, and Henry J. Steinman, for the petitioners.

Lawrence S. Kartiganer and Michael P. McLeod, for the respondent.

Atkins, Judge.

ATKINS

2Cases cited14 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Hort v. CommissionerSupreme Court of the United States · 1941
  5. Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960

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