Cox v. Commissioner
United States Tax Court
All of petitioners' corporate stock was redeemed pursuant to a contract providing for a cash downpayment, transfer of a one-half interest in a lease-option on real estate, and a deferred balance represented by a non-interest-bearing installment promissory note. The parties to the contract amended it 2 years later to provide for interest on the deferred balance.
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All of petitioners' corporate stock was redeemed pursuant to a contract providing for a cash downpayment, transfer of a one-half interest in a lease-option on real estate, and a deferred balance represented by a non-interest-bearing installment promissory note. The parties to the contract amended it 2 years later to provide for interest on the deferred balance. Held, for purposes of installment reporting under sec. 453(b), I.R.C. 1954, the "selling price" does not include interest imputed to deferred payments under sec. 483, I.R.C. 1954, and because the cash downpayment plus the value of the…
1Opinion of the Court
Dean W. Cox and Lavina M. Cox, Petitioners v. Commissioner of Internal Revenue, Respondent
Cox v. Commissioner
Docket No. 3403-72
United States Tax Court
62 T.C. 247; 1974 U.S. Tax Ct. LEXIS 106; 62 T.C. No. 28;
May 16, 1974, Filed
Decision will be entered for the respondent.
All of petitioners' corporate stock was redeemed pursuant to a contract providing for a cash downpayment, transfer of a one-half interest in a lease-option on real estate, and a deferred balance represented by a non-interest-bearing installment promissory note. The parties to the contract amended it 2 years later to provide for…
2Cases cited11 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Ruge v. Comm'rUnited States Tax Court · 1956
- William A. And Margaret K. Tombari v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Tombari v. CommissionerUnited States Tax Court · 1960
- Group Life & Health Insurance Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
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