Estate of Campbell v. Commissioner
United States Tax Court
1. Certain "service stock" was unrestricted when first acquired by promoter; it was later placed in escrow and subjected to certain restrictions.
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1. Certain "service stock" was unrestricted when first acquired by promoter; it was later placed in escrow and subjected to certain restrictions. Held, gain thereafter realized by promoter upon subsequent sales of his rights in such escrowed stock was capital gain rather than ordinary income. 2. Held, petitioners failed to carry burden of proving error in Commissioner's determination that an item of $ 8,217.91 represented unreported income. 3. Held, in the light of a history of filing joint returns over a period of years and of the wife's reliance upon her husband in their financial affairs,…
1Opinion of the Court
Estate of Ralph B. Campbell, Deceased (Mabel W. Campbell, Administratrix), and Mabel W. Campbell, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Campbell v. Commissioner
Docket Nos. 2540-68, 2831-68
United States Tax Court
56 T.C. 1; 1971 U.S. Tax Ct. LEXIS 157;
April 6, 1971, Filed
Decisions will be entered under Rule 50.
1. Certain "service stock" was unrestricted when first acquired by promoter; it was later placed in escrow and subjected to certain restrictions. Held, gain thereafter realized by promoter upon subsequent sales of his rights in such escrowed stock was…
2Cases cited27 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Howell v. CommissionerUnited States Tax Court · 1948
- Kann v. Commissioner of Internal Revenue. Kann's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
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