Adams v. Commissioner
United States Tax Court
Petitioner Robert W. Adams in two related transactions first transferred all of his equity interest in Two States Uranium Corp. to Wyoming Mining & Milling Co. in exchange for Wyoming stock. Next, he sold a valuable mining claim to Wyoming and received in exchange Wyoming's note for $ 1 million. Wyoming then built a device to concentrate uranium ore at the mine site and leased the mining property and preconcentrator to Western for royalties and rent.
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Petitioner Robert W. Adams in two related transactions first transferred all of his equity interest in Two States Uranium Corp. to Wyoming Mining & Milling Co. in exchange for Wyoming stock. Next, he sold a valuable mining claim to Wyoming and received in exchange Wyoming's note for $ 1 million. Wyoming then built a device to concentrate uranium ore at the mine site and leased the mining property and preconcentrator to Western for royalties and rent. Western advanced Wyoming $ 940,000 on the lease and Wyoming used this sum to complete payment of the note to petitioner. Before the advance…
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in the Federal income taxes of the petitioners, as follows:
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Additionally, respondent by an amended answer filed March 17,1971, requested in docket No. 5463-68 an increased deficiency against Wyoming Mining & Milling Co. and increased transferee liability against Robert W. Adams, as shown:
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After certain concessions by each party, the following questions remain for our consideration:(1) Whether an exchange of a uranium mine for a purported debt instrument was a transfer within section 351.2(2) Whether the purported debt…
2Cases cited43 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Crane v. CommissionerSupreme Court of the United States · 1947
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Anderson v. HelveringSupreme Court of the United States · 1940
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
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3Cited by12 opinions
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