Harris v. Commissioner
United States Tax Court
Upon the record, held: That the realities and substance of several steps taken by the petitioner, Glen Harris, and his brother, Darrol Harris, rather than the form, are such as to require treating the steps taken as constituting one transaction for tax purposes; that the realities and substance of the formal steps taken, when viewed as constituting one transaction in substance, are that Glen bought Darrol's undivided one-fourth interest in jointly-owned farm properties,…
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Upon the record, held: That the realities and substance of several steps taken by the petitioner, Glen Harris, and his brother, Darrol Harris, rather than the form, are such as to require treating the steps taken as constituting one transaction for tax purposes; that the realities and substance of the formal steps taken, when viewed as constituting one transaction in substance, are that Glen bought Darrol's undivided one-fourth interest in jointly-owned farm properties, consisting of both the depreciable and nondepreciable assets; that the purported exchange of depreciable assets for…
1Opinion of the Court
Glen R. Harris and Dixie Harris, et al. 1 v. Commissioner.
Harris v. Commissioner
Docket Nos. 5286-65 - 5288-65.
United States Tax Court
T.C. Memo 1968-86; 1968 Tax Ct. Memo LEXIS 211; 27 T.C.M. (CCH) 405; T.C.M. (RIA) 68086;
May 14, 1968. Filed
Upon the record, held: That the realities and substance of several steps taken by the petitioner, Glen Harris, and his brother, Darrol Harris, rather than the form, are such as to require treating the steps taken as constituting one transaction for tax purposes; that the realities and substance of the formal steps taken, when viewed as constituting one…
2Cases cited11 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Hotaling v. HotalingCalifornia Supreme Court · 1924
- Kanawha Gas & Utilities Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Glen R. Harris Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971