Harris v. Commissioner
United States Tax Court
Robert A. Eubanks, guardian, entered into negotiations for the sale of a parcel of improved real estate belonging to petitioner, Nannie Carr Harris, incompetent.
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Robert A. Eubanks, guardian, entered into negotiations for the sale of a parcel of improved real estate belonging to petitioner, Nannie Carr Harris, incompetent. Pursuant to court order, $ 110,000 of the proceeds from this sale was deposited in an irrevocable escrow account on Jan. 17, 1964, payable in installments to Harris over a period of 4 years commencing on January 2, 1965. Held, petitioner is entitled to use installment sale provisions of section 453 since she did not constructively receive in 1964 $ 110,000 deposited in the irrevocable escrow account. Held, further, petitioner Harris…
1Opinion of the Court
Nannie Carr Harris, Incompetent, Robert A. Eubanks, Guardian, Petitioner v. Commissioner of Internal Revenue, Respondent
Harris v. Commissioner
Docket No. 5926-68
United States Tax Court
56 T.C. 1165; 1971 U.S. Tax Ct. LEXIS 71;
August 24, 1971, Filed
Decision will be entered under Rule 50.
Robert A. Eubanks, guardian, entered into negotiations for the sale of a parcel of improved real estate belonging to petitioner, Nannie Carr Harris, incompetent. Pursuant to court order, $ 110,000 of the proceeds from this sale was deposited in an irrevocable escrow account on Jan. 17, 1964, payable in…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. TowerSupreme Court of the United States · 1946
- Burnet v. HarmelSupreme Court of the United States · 1932
- Avery v. CommissionerSupreme Court of the United States · 1934
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