Legal Opinion

Branham v. Commissioner

United States Tax Court

Decided October 28, 1968No. Docket No. 2956-67Published

In 1960 petitioner sold certain property for cash and a 10-year note providing for equal annual payments. He duly elected to report the gain from the sale under the installment method of reporting provided for in sec. 453, I.R.C. 1954. In December 1961 petitioner and his three daughters entered into contracts under which he bought stock belonging to them.

Read the full summary

In 1960 petitioner sold certain property for cash and a 10-year note providing for equal annual payments. He duly elected to report the gain from the sale under the installment method of reporting provided for in sec. 453, I.R.C. 1954. In December 1961 petitioner and his three daughters entered into contracts under which he bought stock belonging to them. The contracts were amended in April 1962. Under the contracts, as amended, petitioner received his daughters' stock in return for cash and his promissory notes. These notes were purportedly secured by petitioner's assignment of three…

1Opinion of the Court

JOE D. BRANHAM AND BLANCHE M. BRANHAM, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

Branham v. Commissioner

Docket No. 2956-67.

United States Tax Court

51 T.C. 175; 1968 U.S. Tax Ct. LEXIS 35;

October 28, 1968. Filed

In 1960 petitioner sold certain property for cash and a 10-year note providing for equal annual payments. He duly elected to report the gain from the sale under the installment method of reporting provided for in sec. 453, I.R.C. 1954. In December 1961 petitioner and his three daughters entered into contracts under which he bought stock belonging to them. The contracts…

2Cases cited4 opinions

  1. Mayerson v. CommissionerUnited States Tax Court · 1966
  2. Branham v. CommissionerUnited States Tax Court · 1968
  3. Robinson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1934
  4. Robinson v. CommissionerUnited States Board of Tax Appeals · 1933

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API