Murray v. Commissioner
United States Board of Tax Appeals
Where more than 75 percent of the purchase price of personal property was placed in escrow as security for petitioners' agreement to refrain from entering a competing business, and the escrow agent was instructed to release one fifth of the escrow funds each year provided the vendor had not entered a competing business, the vendor is entitled to report the profits resulting from the sale on the installment basis, and receipt of the balance of the purchase price by the escrow…
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Where more than 75 percent of the purchase price of personal property was placed in escrow as security for petitioners' agreement to refrain from entering a competing business, and the escrow agent was instructed to release one fifth of the escrow funds each year provided the vendor had not entered a competing business, the vendor is entitled to report the profits resulting from the sale on the installment basis, and receipt of the balance of the purchase price by the escrow agent does not constitute constructive receipt to the vendor, even though the latter has the right to invest and…
1Opinion of the Court
REBECCA J. MURRAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
EDWARD J. MURRAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Murray v. Commissioner
Docket Nos. 40174, 40176, 58857, 58858.
United States Board of Tax Appeals
28 B.T.A. 624; 1933 BTA LEXIS 1093;
July 6, 1933, Promulgated
Where more than 75 percent of the purchase price of personal property was placed in escrow as security for petitioners' agreement to refrain from entering a competing business, and the escrow agent was instructed to release one fifth of the escrow funds each year provided the vendor had…
2Cases cited1 opinion
- Murray v. CommissionerUnited States Board of Tax Appeals · 1933