Legal Opinion

Trottman v. Commissioner

United States Tax Court

Decided April 5, 1944No. Docket No. 112463UnpublishedCited by 1 opinion

Capital gains and losses: Assignment of purchase contract installments for annuity agreement: Gain from exchange of capital assets v. ordinary gain. - In determining the present value of the consideration paid by taxpayer for acquisition of an assigned purchase contract, annuity payments, as base cost, must be discounted, and the gain realized on payments received under the assigned purchase contract is not taxable as capital gain.

1Opinion of the Court

Nelson Trottman and Gwendolen S. Trottman v. Commissioner.

Trottman v. Commissioner

Docket No. 112463.

United States Tax Court

1944 Tax Ct. Memo LEXIS 299; 3 T.C.M. (CCH) 316; T.C.M. (RIA) 44112;

April 5, 1944

Capital gains and losses: Assignment of purchase contract installments for annuity agreement: Gain from exchange of capital assets v. ordinary gain. - In determining the present value of the consideration paid by taxpayer for acquisition of an assigned purchase contract, annuity payments, as base cost, must be discounted, and the gain realized on payments received under the assigned purchase…

2Cases cited5 opinions

  1. Blair v. CommissionerSupreme Court of the United States · 1937
  2. Hopkinson v. CommissionerUnited States Board of Tax Appeals · 1940
  3. Guthrie v. CommissionerUnited States Board of Tax Appeals · 1940
  4. Beck-Brown Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1942
  5. Ettinger v. CommissionerUnited States Board of Tax Appeals · 1937

3Cited by1 opinion

  1. Bratter v. United StatesDistrict Court, S.D. New York · 1958

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