Legal Opinion

Jack Ammann Photogrammetric Engineers, Inc. v. Commissioner

United States Tax Court

Decided December 5, 1962No. Docket No. 85717Published

Petitioner acquired its own obligation, which had been treated by the holder thereof as an installment obligation, in a transaction to which section 351 applies. At the time of the exchange the transferor had certain unreported installment gain. Held: Petitioner took the obligation, albeit its own obligation, as an installment obligation and at its transferor's basis.

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Petitioner acquired its own obligation, which had been treated by the holder thereof as an installment obligation, in a transaction to which section 351 applies. At the time of the exchange the transferor had certain unreported installment gain. Held: Petitioner took the obligation, albeit its own obligation, as an installment obligation and at its transferor's basis. When petitioner canceled the obligation, either by the physical act of making appropriate book entries, or by merger of estates of debtor and creditor, it "disposed of" an installment obligation within the meaning of section…

1Opinion of the Court

Jack Ammann Photogrammetric Engineers, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Jack Ammann Photogrammetric Engineers, Inc. v. Commissioner

Docket No. 85717

United States Tax Court

39 T.C. 500; 1962 U.S. Tax Ct. LEXIS 14;

December 5, 1962, Filed

Decision will be entered under Rule 50.

Petitioner acquired its own obligation, which had been treated by the holder thereof as an installment obligation, in a transaction to which section 351 applies. At the time of the exchange the transferor had certain unreported installment gain. Held: Petitioner took the obligation, albeit its…

2Cases cited6 opinions

  1. Burrell Groves, Inc. v. CommissionerUnited States Tax Court · 1954
  2. Meagher v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Nebraska Seed Co. v. United StatesUnited States Court of Claims · 1953
  4. Wobbers, Inc. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Advance Aluminum Castings Corp. v. HarrisonCourt of Appeals for the Seventh Circuit · 1946

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