Legal Opinion

Hughes v. Commissioner

United States Tax Court

Decided May 21, 1970No. Docket No. 1252-68PublishedCited by 1 opinion

Petitioners agreed to convey to WRI the lot on which their principal dwelling house was situated and to remove the dwelling therefrom. In exchange, they received $ 20,000 in cash and the right to possess, for their lives, certain other residential property nearby owned by WRI, which interest had a value of $ 36,588. Petitioners moved into the latter residence and thereafter continued to occupy it as their only place of abode.

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Petitioners agreed to convey to WRI the lot on which their principal dwelling house was situated and to remove the dwelling therefrom. In exchange, they received $ 20,000 in cash and the right to possess, for their lives, certain other residential property nearby owned by WRI, which interest had a value of $ 36,588. Petitioners moved into the latter residence and thereafter continued to occupy it as their only place of abode. At or about the same time, they purchased another lot and moved their former dwelling to that location. Held, none of the gain realized on the exchange of the lot…

1Opinion of the Court

opinion

In September 1961, petitioners occupied premises A, consisting of a dwelling house and lot, as their principal place of abode. On September 12, 1961, the petitioners agreed to convey to WRI the land on which the petitioners’ dwelling was situated and to remove the' dwelling therefrom. In exchange, they received $20,000 in cash and the right to possess, for their lives, other residential property (premises B). On September 16, 1961, they acquired by purchase a parcel of land (premises C), and subsequently moved their former dwelling to that location where it has since been used as…

2Cases cited7 opinions

  1. Standard Linen Service, Inc. v. CommissionerUnited States Tax Court · 1959
  2. Willow Terrace Dev. Co. v. CommissionerUnited States Tax Court · 1963
  3. Wooten v. CommissionerUnited States Tax Court · 1949
  4. O'Barr v. CommissionerUnited States Tax Court · 1965
  5. Samuel E. Bogley and Anita C. Bogley v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959

2 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Hughes v. CommissionerUnited States Tax Court · 1970

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