Moradian v. Commissioner
United States Tax Court
Petitioner purchased vendor's undivided one-half interest in certain sec. 38 assets. Petitioner's husband owned the remaining one-half interest in such property. Prior to the purchase, such assets were used by a farming partnership in which the vendor and petitioner's husband each owned a 50-percent interest. Following the purchase, such assets continued to be used by a new partnership, in which petitioner and her husband each owned a 50-percent interest.
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Petitioner purchased vendor's undivided one-half interest in certain sec. 38 assets. Petitioner's husband owned the remaining one-half interest in such property. Prior to the purchase, such assets were used by a farming partnership in which the vendor and petitioner's husband each owned a 50-percent interest. Following the purchase, such assets continued to be used by a new partnership, in which petitioner and her husband each owned a 50-percent interest. Held: Petitioner is entitled to an investment credit on her purchase of such assets. Such assets constitute "used section 38 property"…
1Opinion of the Court
Edward A. Moradian and Georgia Moradian, Petitioners v. Commissioner of Internal Revenue, Respondent
Moradian v. Commissioner
Docket No. 3228-67
United States Tax Court
53 T.C. 207; 1969 U.S. Tax Ct. LEXIS 24;
November 12, 1969, Filed
Decision will be entered under Rule 50.
Petitioner purchased vendor's undivided one-half interest in certain sec. 38 assets. Petitioner's husband owned the remaining one-half interest in such property. Prior to the purchase, such assets were used by a farming partnership in which the vendor and petitioner's husband each owned a 50-percent interest. Following the…
Also in this document: Dissent · Scott; Dissent · Tannenwald.
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
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