Hager v. Commissioner
United States Tax Court
In 1971, Ps became limited partners of X. At the same time, X purchased 107 head of imported cattle from Y, a related entity, for $ 1,614,000. As consideration for the purchase, X paid $ 20,000 in cash, executed a short-term note for $ 529,000 on which it was liable, and executed a nonrecourse promissory note, secured by the cattle, for $ 1,065,000. In 1971, there was no established market price in the United States for such cattle, but during that year, such cattle normally…
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In 1971, Ps became limited partners of X. At the same time, X purchased 107 head of imported cattle from Y, a related entity, for $ 1,614,000. As consideration for the purchase, X paid $ 20,000 in cash, executed a short-term note for $ 529,000 on which it was liable, and executed a nonrecourse promissory note, secured by the cattle, for $ 1,065,000. In 1971, there was no established market price in the United States for such cattle, but during that year, such cattle normally sold in England for less than $ 1,000 per animal. Held: 1. The purchase price paid by X for the cattle was at least 3…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes:
Petitioners Year Deficiency
Edward B. Hager. 1971 $10,345.57
Edward B. Hager
and Jane E. Hager. 1972 8,132.62
1973 18,964.17
Constantine L. Hampers
and Lavonne J. Hampers. 1971 13,731.00
1972 2,971.00
1973 3,459.00
The Commissioner concedes that his determination of a deficiency in the tax of Dr. and Mrs. Hager for 1973 was the result of a mathematical error and that, in fact, Dr. and Mrs. Hager overpaid their tax for 1973 by $18,964.17. However, such taxable year remains in issue for…
2Cases cited23 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Crane v. CommissionerSupreme Court of the United States · 1947
- Golanty v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
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3Cited by117 opinions
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- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Siegel v. CommissionerUnited States Tax Court · 1982
- Flowers v. CommissionerUnited States Tax Court · 1983
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