Kovens v. Commissioner
United States Tax Court
Petitioner owned stock of a corporation that held a long-term lease to a hospital. In 1966, he sold to a tax-exempt entity (the same hospital) corporate stock sufficient in amount to transfer the hospital lease to the purchaser.
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Petitioner owned stock of a corporation that held a long-term lease to a hospital. In 1966, he sold to a tax-exempt entity (the same hospital) corporate stock sufficient in amount to transfer the hospital lease to the purchaser. The purchase agreement provided for an $800,000 downpayment, a contingent downpayment of $1,200,000, assumption of $2,173,000 in liabilities, plus the greater of $3,500,000 (payable in yearly installments of $233,333) or two-thirds of the adjusted net profits of their hospital. Held, all gain to petitioner on the stock sale is capital gain. Berenson v. Commissioner,59…
1Opinion of the Court
CALVIN KOVENS, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kovens v. Commissioner
Docket Nos. 5327-72, 240-76, 241-76.
United States Tax Court
T.C. Memo 1983-391; 1983 Tax Ct. Memo LEXIS 394; 46 T.C.M. (CCH) 657; T.C.M. (RIA) 83391;
July 7, 1983.
Petitioner owned stock of a corporation that held a long-term lease to a hospital. In 1966, he sold to a tax-exempt entity (the same hospital) corporate stock sufficient in amount to transfer the hospital lease to the purchaser. The purchase agreement provided for an $800,000 downpayment, a contingent downpayment of $1,200,000,…
2Cases cited14 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. GilmoreSupreme Court of the United States · 1963
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. TellierSupreme Court of the United States · 1966
- Estate of Scharf v. CommissionerUnited States Tax Court · 1962
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