Goff v. Commissioner
United States Tax Court
Capital Gain -- Cancellation of a Contract -- Section 117 (a) (4). -- The cancellation of a contract under which the petitioner had the exclusive right for a period of years to hosiery produced by machines owned by another was a sale or exchange within section 117 (a) (4) since there was thereby transferred to the owner valuable property rights in the machines.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies in income tax for 1947 as follows:
Doa. No. Petitioner Amount
34643_Henrietta B. Goff_$7,705.24
34644_Rebecca Hirschwald_ 8,259.83
34645_Thomas V. and Barbara P. Maride_ 20,423.71
34646_David Rosen_ 1,629.01
34647_Julia B. Sanson_ 21,826.90
The only issue which has not been conceded or settled by stipulation is whether the gain realized by Saxon Hosiery Mills, hereafter called Saxon, a partnership for income tax purposes, from a transaction on June 30,1946, in which it gave up all of its rights under an agreement dated August 30,1941,…
2Cases cited6 opinions
- Commissioner of Internal Revenue v. Golonsky. Commissioner of Internal Revenue v. GoldCourt of Appeals for the Third Circuit · 1952
- Jones, Collector of Internal Revenue v. CorbynCourt of Appeals for the Tenth Circuit · 1950
- Golonsky v. CommissionerUnited States Tax Court · 1951
- Ray v. CommissionerUnited States Tax Court · 1952
- McCue Bros. & Drummond, Inc. v. CommissionerUnited States Tax Court · 1953
1 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Leh v. CommissionerUnited States Tax Court · 1957
- Hollywood Baseball Ass'n v. CommissionerUnited States Tax Court · 1964
- Pittston Co. v. CommissionerUnited States Tax Court · 1956
- Hallcraft Homes, Inc. v. CommissionerUnited States Tax Court · 1963
- Commissioner v. GoffCourt of Appeals for the Third Circuit · 1954
11 more not listed; retrieve them via the Exa API.