Dennis v. Commissioner
United States Tax Court
Promissory note for $ 1,500,000 not in registered form or with interest coupons at time of issuance or on Mar. 1, 1954, payable in monthly installments of $ 10,000 for 12 1/2 years, received with 40 percent of stock, in exchange for transfer of undivided one-half interest in patent rights to corporation, capitalized at $ 10,000, at time of incorporation on Oct. 1, 1953, held to be security within meaning of sec. 112(b)(5), I.R.C. 1939, and payments received in retirement…
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Promissory note for $ 1,500,000 not in registered form or with interest coupons at time of issuance or on Mar. 1, 1954, payable in monthly installments of $ 10,000 for 12 1/2 years, received with 40 percent of stock, in exchange for transfer of undivided one-half interest in patent rights to corporation, capitalized at $ 10,000, at time of incorporation on Oct. 1, 1953, held to be security within meaning of sec. 112(b)(5), I.R.C. 1939, and payments received in retirement thereof are taxable as ordinary income.
1Opinion of the Court
Clement O. Dennis and Genia Lee Dennis, Petitioners v. Commissioner of Internal Revenue, Respondent
Dennis v. Commissioner
Docket No. 772-70
United States Tax Court
57 T.C. 352; 1971 U.S. Tax Ct. LEXIS 11; 57 T.C. No. 35;
December 13, 1971, Filed
Decision will be entered for respondent.
Promissory note for $ 1,500,000 not in registered form or with interest coupons at time of issuance or on Mar. 1, 1954, payable in monthly installments of $ 10,000 for 12 1/2 years, received with 40 percent of stock, in exchange for transfer of undivided one-half interest in patent rights to corporation, capitalized…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Camp Wolters Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
- Baker Commodities, Inc., a California Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1969
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