Robinson v. Commissioner
United States Tax Court
On Jan. 10, 1964, the petitioner sold his business under a contract providing for payments in installments without interest. At that time, the transaction met all the requirements of sec. 453(b) of the Internal Revenue Code of 1954 for the reporting of the gain on the installment method.
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On Jan. 10, 1964, the petitioner sold his business under a contract providing for payments in installments without interest. At that time, the transaction met all the requirements of sec. 453(b) of the Internal Revenue Code of 1954 for the reporting of the gain on the installment method. On Feb. 26, 1964, Congress enacted sec. 483 of the Code which provided that, for purposes of the Code, where no interest payments are specified with respect to certain installment payments, a part of each installment payment shall be treated as interest. It was provided that sec. 483 should apply to payments…
1Opinion of the Court
Raymond Robinson and Lillie H. Robinson, Petitioners v. Commissioner of Internal Revenue, Respondent
Robinson v. Commissioner
Docket No. 5597-67
United States Tax Court
54 T.C. 772; 1970 U.S. Tax Ct. LEXIS 163;
April 15, 1970, Filed
Decision will be entered for the respondent.
On Jan. 10, 1964, the petitioner sold his business under a contract providing for payments in installments without interest. At that time, the transaction met all the requirements of sec. 453(b) of the Internal Revenue Code of 1954 for the reporting of the gain on the installment method. On Feb. 26, 1964, Congress enacted sec.…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Chew Heong v. United StatesSupreme Court of the United States · 1884
- Fullerton-Krueger Lumber Co. v. Northern Pacific Railway Co.Supreme Court of the United States · 1925
- Twenty Per Cent. CasesSupreme Court of the United States · 1874
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