Estate of Bowers v. Commissioner
United States Tax Court
T entered into an agreement of Apr. 28, 1982, to sell his Federal oil and gas lease to AQ Co. (AQ) for $ 2 million, which paid $ 400,000 earnest money therefor in May 1982. On some undisclosed date prior to July 1982, Browne Land Trust contracted to purchase a farm and related Federal Land Bank stock from an undisclosed seller for $ 877,000. The trust had no connection either with T or with AQ.
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T entered into an agreement of Apr. 28, 1982, to sell his Federal oil and gas lease to AQ Co. (AQ) for $ 2 million, which paid $ 400,000 earnest money therefor in May 1982. On some undisclosed date prior to July 1982, Browne Land Trust contracted to purchase a farm and related Federal Land Bank stock from an undisclosed seller for $ 877,000. The trust had no connection either with T or with AQ. The trust agreed on July 6, 1982, to transfer its interest in the farm to T for an additional $ 200,000. On July 7, 1982, the trust purchased the farm and stock, making payment therefor in part with…
1Opinion of the Court
OPINION
Raum, Judge:
Petitioner is the Estate of Alexander S. Bowers. The Commissioner determined deficiencies in the decedent’s income tax for the calendar years 1982 and 1983 in the amounts of $43,211.42 and $216,851, respectively. The decedent was a resident of Virginia, and Robert M. Musselman, executor of his estate, was also a resident of Virginia when the petition herein was filed. After concessions, the parties agree that the only remaining issue is whether decedent’s transfer of an oil and gas lease, and acquisition of a farm constituted an “exchange” which qualifies for nonrecognition…
2Cases cited26 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Bank of Commerce v. Tennessee Ex Rel. MemphisSupreme Court of the United States · 1896
- June Pinson Carlton and Charles T. Carlton, as Administrators of the Estate of Thad H. Carlton, and June Carlton v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Biggs v. CommissionerUnited States Tax Court · 1978
21 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
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- DeCleene v. CommissionerUnited States Tax Court · 2000
- Leila G. Newhall Unitrust v. CommissionerUnited States Tax Court · 1995
- Van Zelst v. CommissionerUnited States Tax Court · 1995
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