Buse v. Commissioner
United States Tax Court
The State of Washington contractually conveyed certain timber to taxpayer. The contract provided for a removal period which expired Dec. 31, 1971. Subsequent agreements extended the removal period. The first agreement allowed for removal of timber between Dec. 31, 1971, and Dec. 31, 1972; the second extension allowed for timber removal between Dec. 31, 1972, and Dec. 31, 1973. Neither extension was formally executed prior to the termination of the previous removal period.
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The State of Washington contractually conveyed certain timber to taxpayer. The contract provided for a removal period which expired Dec. 31, 1971. Subsequent agreements extended the removal period. The first agreement allowed for removal of timber between Dec. 31, 1971, and Dec. 31, 1972; the second extension allowed for timber removal between Dec. 31, 1972, and Dec. 31, 1973. Neither extension was formally executed prior to the termination of the previous removal period. Held, for purposes of sec. 631(a), I.R.C. 1954, taxpayer owned or held the timber for the requisite period. Held, further,…
1Opinion of the Court
Sterrett, Judge:
Respondent, on March 29,1976, issued statutory notices in which he determined deficiencies in, and additions to, the respective petitioners’ Federal income taxes as follows:
Norman M. Buse and Antoinette Buse _Additions to tax under_
Year ended Dec. 31— Deficiency Sec. 6651(a) Sec. 6653(a)
1972 . $70,707
1973 . 50,946 ($577.10)
1974 . 252,451 $12,623
Delmer H. Buse and Mary Buse Addition to tax under
Year ended Dec. 31— Deficiency Sec. 6653(a)
1972 . $71,292
1973 . 50,946
1974 . 251,735 $12,587
Our decision herein is limited to the following issues with respect to section 631(a), I.R.C.…
2Cases cited2 opinions
- Boeing Airplane Co. v. Firemen's Fund Indemnity Co.Washington Supreme Court · 1954
- Wasser & Winters Co. v. Jefferson CountyWashington Supreme Court · 1975
3Cited by12 opinions
- Estate of Ford v. CommissionerUnited States Tax Court · 1993
- Willamette Industries, Inc. v. CommissionerUnited States Tax Court · 1987
- Klukwan, Inc. v. CommissionerUnited States Tax Court · 1994
- Willamette Indus. v. CommissionerUnited States Tax Court · 1992
- Willamette Industries, Inc. v. CommissionerUnited States Tax Court · 1991
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