Hassen v. Commissioner
United States Tax Court
1. As a consequence of the individual petitioners' default on a note which was secured by a trust deed pledging their real property community asset, Pacific, the holder of the note, foreclosed, and at the trustee's sale on May 31, 1961, purchased the property for the outstanding balance of the note.
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1. As a consequence of the individual petitioners' default on a note which was secured by a trust deed pledging their real property community asset, Pacific, the holder of the note, foreclosed, and at the trustee's sale on May 31, 1961, purchased the property for the outstanding balance of the note. A few days prior to the trustee's sale, an officer of Pacific stated to one of petitioners that if Pacific bought in the property petitioner or his designate would be given the first right to purchase it for the outstanding balance of the note and foreclosure costs. On June 5, 1961, U.L.C.,…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and additions thereto under sections 6651(a) and 6653(a), I.R.C. 1954,2 as follows:
Petitioner Docket No. Year Addition to tax Deficiency Sec. 6651(a) Sec. 6653(a)
E.E. Hassen and B.B. Hassen 1644-68 1965 $4,764.00
Erwin E. Hassen and Birdie B. Hassen 3686-68 1959 1961 1962 73,177.85 2,156.85 189,795.65 $3,658.89 107.84 9,489.78
Erwin E. Hassen and Birdie B. Hassen 4030-68 1963 24,859.68 1,242.98
Vinemore Co., Inc. 3687-68 FY ending 8/31/62 69,601.05 4066-68 FY ending 8/31/63 17,114.50 FY ending 8/31/64 31,539.17…
2Cases cited16 opinions
- Commissioner v. GordonSupreme Court of the United States · 1968
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
- Ayoob v. AyoobCalifornia Court of Appeal · 1946
- Robert H. McNeill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
11 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Davis v. CommissionerUnited States Tax Court · 1987
- Frank C. Davis, Jr. And Frank C. Davis, Jr., of the Estate of Grace K. Davis v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Unionbancal Corp. v. CommissionerUnited States Tax Court · 1999
- Tracinda Corp. v. CommissionerUnited States Tax Court · 1998
- Erwin E. Hassen and Estate of Birdie B. Hassen, Deceased, Nathan Hassen, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
12 more not listed; retrieve them via the Exa API.