Wrenn v. Commissioner
United States Tax Court
Petitioners are husband and wife who effected a sale of various securities from husband to wife in 1973. All securities were transferred at date of sale while payments were to be made in monthly installments over a 15-year period. The sale was valid in all respects under Oregon law. Immediately after this transfer, the wife disposed of the shares she had received.
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Petitioners are husband and wife who effected a sale of various securities from husband to wife in 1973. All securities were transferred at date of sale while payments were to be made in monthly installments over a 15-year period. The sale was valid in all respects under Oregon law. Immediately after this transfer, the wife disposed of the shares she had received. Shortly thereafter she purchased shares in a specified mutual fund in an amount equal to the proceeds of sale in order to satisfy a security obligation arising out of the original installment purchase. Held, petitioners are not…
1Opinion of the Court
OPINION
Dawson, Chief Judge:
Respondent determined a deficiency of $56,387 in petitioners’ Federal income tax for calendar year 1973. The sole issue presented for decision is whether gain realized by petitioner Philip W. Wrenn from the sale of common stocks to his wife may be reported in annual installments pursuant to the provisions of section 453, I.R.C. 1954.1
This case was submitted for decision without trial in accordance with the provisions of Rule 122, Tax Court Rules of Practice and Procedure. We adopt the stipulation of facts and exhibits attached thereto as our findings. All pertinent…
2Cases cited7 opinions
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Rushing v. CommissionerUnited States Tax Court · 1969
- W. B. Rushing v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Dolan v. CommissionerUnited States Tax Court · 1965
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Pityo v. CommissionerUnited States Tax Court · 1978
- Gordon v. CommissionerUnited States Tax Court · 1985
- Goodman v. CommissionerUnited States Tax Court · 1980
- Lustgarten v. CommissionerUnited States Tax Court · 1978
- Roberts v. CommissionerUnited States Tax Court · 1978
21 more not listed; retrieve them via the Exa API.