Hammerstrom v. Commissioner
United States Tax Court
Petitioner and her former husband, at the time of their divorce on Oct. 13, 1967, converted the form of the joint ownership of their business assets from community property to tenancy in common. Five days later, under the terms of the property settlement agreement, the former husband wrote petitioner a letter "electing" to purchase petitioner's interest in the business assets and requesting that petitioner enter into an agreement of purchase.
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Petitioner and her former husband, at the time of their divorce on Oct. 13, 1967, converted the form of the joint ownership of their business assets from community property to tenancy in common. Five days later, under the terms of the property settlement agreement, the former husband wrote petitioner a letter "electing" to purchase petitioner's interest in the business assets and requesting that petitioner enter into an agreement of purchase. The parties, however, were unable to agree on details of the purchase and nothing further was done until 1972. Held, the transmutation of the business…
1Opinion of the Court
Frank R. Hammerstrom and Jewel Hammerstrom, Petitioners v. Commissioner of Internal Revenue, Respondent
Hammerstrom v. Commissioner
Docket No. 5736-71
United States Tax Court
60 T.C. 167; 1973 U.S. Tax Ct. LEXIS 133; 60 T.C. No. 21;
May 7, 1973, Filed
Decision will be entered under Rule 50.
Petitioner and her former husband, at the time of their divorce on Oct. 13, 1967, converted the form of the joint ownership of their business assets from community property to tenancy in common. Five days later, under the terms of the property settlement agreement, the former husband wrote petitioner a letter…
2Cases cited8 opinions
- Poe v. SeabornSupreme Court of the United States · 1930
- Commissioner v. BrownSupreme Court of the United States · 1965
- United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
- 2 Lexington Ave. Corp. v. CommissionerUnited States Tax Court · 1956
- Dezendorf v. CommissionerCourt of Appeals for the Fifth Circuit · 1963
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