Watson v. Commissioner
United States Tax Court
Pursuant to a deferred payment agreement, petitioner sold 147 bales of cotton on Nov. 29, 1973, and as consideration for the sale, received from a local bank an irrevocable banker's letter of credit in the amount of $ 42,146.51, which the bank guaranteed to accept and honor on Jan. 10, 1974. Held, petitioner received taxable income in 1973 when the banker's letter of credit was delivered to him.
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in the amount of $23,319.41 in petitioners’ Federal income tax for 1973. A concession on another issue having been made by petitioners, the sole issue remaining for decision is whether petitioners realized income of $42,146.51 in 1973 from the sale of 147 bales of cotton under terms pursuant to which they received an irrevocable letter of credit from a local bank in that year.
FINDINGS OF FACT
Petitioners H. N. Watson, Jr., and Shirley Watson, husband and wife, were legal residents of Ralls, Tex., when they filed their petition. They filed a…
2Cases cited11 opinions
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- H. O. Williams and Mrs. Ada L. Williams v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Barclays Bank D. C. O. v. Mercantile National BankCourt of Appeals for the Fifth Circuit · 1973
- Sproull v. CommissionerUnited States Tax Court · 1951
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3Cited by18 opinions
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- Griffith v. CommissionerUnited States Tax Court · 1980
- Willamette Indus. v. CommissionerUnited States Tax Court · 1989
- R. Paul Sprague and Mary G. Sprague v. United StatesCourt of Appeals for the Tenth Circuit · 1980
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
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