Legal Opinion

Connell v. Commissioner

United States Tax Court

Decided July 20, 1981No. Docket No. 10233-78Unpublished

Petitioner sold his 51-percent interest in a trailer park to Deen and reported the sale on the installment method as prescribed in sec. 453, I.R.C. 1954. As part of the consideration for such sale, Deen executed a $ 230,000 note in petitioner's favor. Prior to this sale, petitioner had been indebted to Deen on a $ 200,000 note which originally arose as part of an independent sales transaction.

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Petitioner sold his 51-percent interest in a trailer park to Deen and reported the sale on the installment method as prescribed in sec. 453, I.R.C. 1954. As part of the consideration for such sale, Deen executed a $ 230,000 note in petitioner's favor. Prior to this sale, petitioner had been indebted to Deen on a $ 200,000 note which originally arose as part of an independent sales transaction. Both petitioner and Deen pledged the amounts due them under their respective notes as an additional source of payment to satisfy their obligations under each of the notes. Held, the mutual notes between…

1Opinion of the Court

JOHN L. CONNELL and KETNA S. CONNELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Connell v. Commissioner

Docket No. 10233-78.

United States Tax Court

T.C. Memo 1981-370; 1981 Tax Ct. Memo LEXIS 371; 42 T.C.M. (CCH) 423; T.C.M. (RIA) 81370;

July 20, 1981

Petitioner sold his 51-percent interest in a trailer park to Deen and reported the sale on the installment method as prescribed in sec. 453, I.R.C. 1954. As part of the consideration for such sale, Deen executed a $ 230,000 note in petitioner's favor. Prior to this sale, petitioner had been indebted to Deen on a $ 200,000 note which…

2Cases cited20 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  4. Griffiths v. CommissionerSupreme Court of the United States · 1939
  5. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977

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