Estate of Shea v. Commissioner
United States Tax Court
A corporate taxpayer purchased a ship and charter for a stated consideration. Following the destruction of the ship, the taxpayer sold the charter. Held, the charter was property "subject to an allowance for depreciation," and its sale produced capital gain under sec. 1231(a), I.R.C. 1954.
1Opinion of the Court
Quealt, Judge:
The Commissioner determined deficiencies in the Federal income tax of the petitioners as follows:
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With the mutual consent of the parties, the above-entitled cases have been consolidated for purposes of this opinion. All the issues presented in docket No. 2983-68 have been resolved by the concessions of the parties. As for the other docket numbers, concessions have been made by the parties; and, as a consequence, the sole issue presented for decision is whether the gam, which arose from the disposition of the Metropolitan Petroleum Co. tanker voyage charter party by…
2Cases cited16 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Ferrer v. CommissionerUnited States Tax Court · 1961
11 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Kingsbury v. CommissionerUnited States Tax Court · 1976
- Flower v. CommissionerUnited States Tax Court · 1973
- Michot v. CommissionerUnited States Tax Court · 1982
- Estate of Shea v. CommissionerUnited States Tax Court · 1971
- Flower v. CommissionerUnited States Tax Court · 1973
1 more not listed; retrieve them via the Exa API.