Legal Opinion

Hughes v. Commissioner

United States Board of Tax Appeals

Decided August 23, 1935No. Docket No. 67335Published

1. Payments made under terms of a sales contract by the purchaser of corporation stocks and bonds to the seller to reimburse the latter for Federal income taxes incurred on his profits in the transaction are taxable income to the seller in the year received, and not the year of the sale. 2. On the evidence, the basis used by the respondent in determining the gain from the sale of certain stock is approved.

1Opinion of the Court

E. A. HUGHES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hughes v. Commissioner

Docket No. 67335.

United States Board of Tax Appeals

32 B.T.A. 1248; 1935 BTA LEXIS 827;

August 23, 1935, Promulgated

1. Payments made under terms of a sales contract by the purchaser of corporation stocks and bonds to the seller to reimburse the latter for Federal income taxes incurred on his profits in the transaction are taxable income to the seller in the year received, and not the year of the sale.

2. On the evidence, the basis used by the respondent in determining the gain from the sale of certain…

2Cases cited1 opinion

  1. Hughes v. CommissionerUnited States Board of Tax Appeals · 1935

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