Cunningham v. Commissioner
United States Tax Court
Petitioners sold shares of corporation X to corporation A in December 1958 for cash and installment obligations represented by A's promissory notes. In October 1960, after dissension in the management of corporation A, corporation X's shares were transferred to corporation B which assumed the installment obligation of corporation A on the promissory notes held by petitioners.
Read the full summary
Petitioners sold shares of corporation X to corporation A in December 1958 for cash and installment obligations represented by A's promissory notes. In October 1960, after dissension in the management of corporation A, corporation X's shares were transferred to corporation B which assumed the installment obligation of corporation A on the promissory notes held by petitioners. Held, that this was not a disposition by petitioners of their installment obligations resulting in a taxable gain measured by the excess in value of corporation X's shares when acquired by corporation B over petitioners'…
1Opinion of the Court
John I. Cunningham and Diane W. Cunningham, Petitioners, v. Commissioner of Internal Revenue, Respondent; Weaver Cunningham and Gwendolyn B. Cunningham, Petitioners, v. Commissioner of Internal Revenue, Respondent
Cunningham v. Commissioner
Docket Nos. 5118-63, 5119-63
United States Tax Court
44 T.C. 103; 1965 U.S. Tax Ct. LEXIS 95;
April 27, 1965, Filed
Decisions will be entered for the petitioners.
Petitioners sold shares of corporation X to corporation A in December 1958 for cash and installment obligations represented by A's promissory notes. In October 1960, after dissension in the management…
2Cases cited7 opinions
- Burrell Groves, Inc. v. CommissionerUnited States Tax Court · 1954
- Boca Ratone Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1936
- Wynne v. CommissionerUnited States Board of Tax Appeals · 1942
- Burrell Groves, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Jack Ammann Photogrammetric Engineers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
2 more not listed; retrieve them via the Exa API.