Legal Opinion

Estate of Nordquist v. Commissioner

United States Tax Court

Decided September 11, 1972No. Docket No. 4146-70Unpublished

The petitioner supplied funds to enable another taxpayer to purchase certain stock pursuant to an agreement whereby the petitioner might, at the election of the other taxpayer, receive back either cash or a portion of the stock. When the taxpayer elected to pay the petitioner cash, the resulting gain was not realized on the sale or exchange of a capital asset within the meaning of sec. 1221, I.R.C., 1954.

1Opinion of the Court

Estate of Oscar A. Nordquist, Deceased, Georgiana G. Nordquist, Executrix, and Georgiana G. Nordquist v. Commissioner.

Estate of Nordquist v. Commissioner

Docket No. 4146-70

United States Tax Court

T.C. Memo 1972-198; 1972 Tax Ct. Memo LEXIS 60; 31 T.C.M. (CCH) 994; T.C.M. (RIA) 72198;

September 11, 1972

The petitioner supplied funds to enable another taxpayer to purchase certain stock pursuant to an agreement whereby the petitioner might, at the election of the other taxpayer, receive back either cash or a portion of the stock. When the taxpayer elected to pay the petitioner cash, the resulting…

2Cases cited2 opinions

  1. Elverson Corporation v. HelveringCourt of Appeals for the Second Circuit · 1941
  2. Becher v. CommissionerUnited States Tax Court · 1963

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