Legal Opinion

Hammerstrom v. Commissioner

United States Tax Court

Decided May 7, 1973No. Docket No. 5736-71Published

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

  1. Poe v. SeabornSupreme Court of the United States · 1930
  2. Commissioner v. BrownSupreme Court of the United States · 1965
  3. United States v. MerrillCourt of Appeals for the Ninth Circuit · 1954
  4. 2 Lexington Ave. Corp. v. CommissionerUnited States Tax Court · 1956
  5. Dezendorf v. CommissionerCourt of Appeals for the Fifth Circuit · 1963

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