Lowe v. Commissioner
United States Tax Court
Petitioner in 1955 sold to one Levitus all of the stock of a corporation which had a lease on a hotel. Levitus made a downpayment on the purchase price in 1955, gave petitioner a promissory note for the balance, deposited the shares with him as security, and immediately began managing the hotel.
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Petitioner in 1955 sold to one Levitus all of the stock of a corporation which had a lease on a hotel. Levitus made a downpayment on the purchase price in 1955, gave petitioner a promissory note for the balance, deposited the shares with him as security, and immediately began managing the hotel. Levitus continued such management until he defaulted in payment of the remaining purchase price in 1958. Levitus then reconveyed the stock to taxpayer and taxpayer released him from any further obligation under the 1955 sale. Taxpayer retained $ 22,500 previously paid by Levitus toward the purchase…
1Opinion of the Court
Alvin B. Lowe and Ruth Lowe, Petitioners, v. Commissioner of Internal Revenue, Respondent
Lowe v. Commissioner
Docket No. 4745-62
United States Tax Court
44 T.C. 363; 1965 U.S. Tax Ct. LEXIS 75;
June 11, 1965, Filed
Decision will be entered under Rule 50.
Petitioner in 1955 sold to one Levitus all of the stock of a corporation which had a lease on a hotel. Levitus made a downpayment on the purchase price in 1955, gave petitioner a promissory note for the balance, deposited the shares with him as security, and immediately began managing the hotel. Levitus continued such management until he defaulted…
2Cases cited24 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Osenbach v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
- Dial v. CommissionerUnited States Tax Court · 1955
- Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
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