Schultz v. Commissioner
United States Tax Court
1. On Dec. 31, 1962, petitioner Mortimer L. Schultz sold his holdings in the stock of First Jersey Securities Corp. (FJS) to Office Buildings of America, Inc. (OBA), of which he was president; and as an integral part of the same transaction sold his proprietorship interest and assets in another company which he owned to FJS.
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1. On Dec. 31, 1962, petitioner Mortimer L. Schultz sold his holdings in the stock of First Jersey Securities Corp. (FJS) to Office Buildings of America, Inc. (OBA), of which he was president; and as an integral part of the same transaction sold his proprietorship interest and assets in another company which he owned to FJS. The consideration for both sales, $ 270,500, consisting of cash and notes, was received by him on Dec. 31, 1962. OBA's check was honored immediately upon presentation to the bank, and no express or implied conditions precedent to passing title existed at the time of…
1Opinion of the Court
Withev, Judge:
In these consolidated cases tbe respondent determined tbe following Federal income tax deficiencies and additions to tax under section 6651(a) of tbe Internal Revenue Code of 1954 for the taxable year 1962 as follows:
Petitioner Docket No. Deficiency Addition to tax see. 6651(a)
Mortimer Schultz and Rosanna Schultz. 1830-71 $63,039.28 ...
Roger Schultz. 1831-71 10,287.67 $2,571.92
Patricia Schultz... 1832-71 10,287.67 2,571.92
Karen Schultz. 1833-71 10,287.67 2,571.92
Michael Schultz-. 1834-71 10,287.67 2,571.92
The issues presented for our consideration in docket No. 1830-71 are:(1)…
2Cases cited16 opinions
- James v. United StatesSupreme Court of the United States · 1961
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Healy v. CommissionerSupreme Court of the United States · 1953
- Walet v. CommissionerUnited States Tax Court · 1958
- Safety Tube Corp. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
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