Edgar v. Commissioner
United States Tax Court
1. Neither the individual petitioners who are members of the Strain family nor the trusts which they created in 1963 had recognizable capital gain in 1964 (other than the gain referred to in issue 2) when stock was sold to Brigham Young University; the transaction was not an exchange of stock for annuities, but was a deferred-payment sale by the trusts. 2. Neither William Russell Strain nor Harriet Strain realized taxable income in 1964 on the sale by two trusts of stock…
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1. Neither the individual petitioners who are members of the Strain family nor the trusts which they created in 1963 had recognizable capital gain in 1964 (other than the gain referred to in issue 2) when stock was sold to Brigham Young University; the transaction was not an exchange of stock for annuities, but was a deferred-payment sale by the trusts. 2. Neither William Russell Strain nor Harriet Strain realized taxable income in 1964 on the sale by two trusts of stock which was subject to liens, securing notes previously given by William Russell Strain and Arthur W. Strain; however, the…
1Opinion of the Court
Glenn E. Edgar and Elva Edgar, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Edgar v. Commissioner
Docket Nos. 3237-67, 3340-67, 3341-67, 2911-68 -- 2926-68
United States Tax Court
56 T.C. 717; 1971 U.S. Tax Ct. LEXIS 102;
July 8, 1971, Filed
Decisions will be entered under Rule 50.
1. Neither the individual petitioners who are members of the Strain family nor the trusts which they created in 1963 had recognizable capital gain in 1964 (other than the gain referred to in issue 2) when stock was sold to Brigham Young University; the transaction was not an exchange of stock for…
2Cases cited71 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. LoBueSupreme Court of the United States · 1956
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