Legal Opinion
Merrill N. Bradley and John R. Murray v. United States
Court of Appeals for the Eleventh Circuit
Decided April 23, 1984No. 83-7143PublishedCited by 41 opinions
1Opinion of the Court
HATCHETT, Circuit Judge:
In this tax case, we review the district court’s ruling that the transaction between appellant taxpayers and an Alabama limited partnership constituted a sale of property, rather than an option to purchase, and that the payments derived therefrom were interest income subject to tax assessment under 26 U.S.C.A. § 61(a)(4) (West 1967). We affirm.
Facts
The appellant taxpayers were co-owners of approximately 320 acres of land (hereinafter Lovick property) near Lovick, Alabama. On July 27, 1974, Gary L. Thompson (Thompson) asked appellant, John Murray, to sell him the Lovick…
2Cases cited6 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Bernard D. Spector v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
1 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Coleman v. CommissionerUnited States Tax Court · 1986
- Comdisco, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1985
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
- Illinois Power Co. v. CommissionerUnited States Tax Court · 1986
- United States v. BergbauerCourt of Appeals for the Fourth Circuit · 2010
36 more not listed; retrieve them via the Exa API.