Nelson Weaver Realty Co. v. Commissioner
United States Tax Court
1. Held, the sum of $ 121,841.11 which petitioner Nelson Weaver Mortgage Company, Inc., received from another mortgage corporation, in a transaction whereby it transferred to the latter corporation its interests under a contract to act as an agent for a life insurance company in servicing mortgage loans held by said company, represented consideration for its contingent right to earn future compensation from said life insurance company; and that said sum is taxable as…
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1. Held, the sum of $ 121,841.11 which petitioner Nelson Weaver Mortgage Company, Inc., received from another mortgage corporation, in a transaction whereby it transferred to the latter corporation its interests under a contract to act as an agent for a life insurance company in servicing mortgage loans held by said company, represented consideration for its contingent right to earn future compensation from said life insurance company; and that said sum is taxable as ordinary income, and not as capital gain. 2. Held, the sum of $ 8,000 which petitioner Nelson Weaver Realty Company received…
1Opinion of the Court
Pierce, Judge:
Respondent, in Docket No. 80361, determined a deficiency in the income tax of petitioner Nelson Weaver Mortgage Company, Inc., for its fiscal year ended September 30, 1955, in the amount of $54,192.89. Also, in Docket No. 79957, respondent determined a deficiency in the income tax of petitioner Nelson Weaver Realty Company, for its taxable calendar year 1955, in the amount of $3,666.02.
The cases were consolidated for trial.
The issues for decision are:(1) Whether the sum of $121,841.11 which petitioner Nelson Weaver Mortgage Company, Inc., received from another mortgage…
2Cases cited8 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Arkansas Valley Smelting Co. v. Belden Mining Co.Supreme Court of the United States · 1888
- General Artists Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Brooks v. CommissionerUnited States Tax Court · 1961
- Nelson Weaver Realty Company, and Nelson Weaver Mortgage Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Estate of Scharf v. CommissionerUnited States Tax Court · 1962
- Brown v. CommissionerUnited States Tax Court · 1963
- First Pennsylvania Banking & Trust Co. v. CommissionerUnited States Tax Court · 1971
14 more not listed; retrieve them via the Exa API.