Legal Opinion

William S. Peterson and Betty M. Peterson v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided June 5, 1967No. 20515_1PublishedCited by 5 opinions

1Opinion of the Court

CHAMBERS, Circuit Judge:

William Peterson is a successful promoter of cemeteries. Like most of us, he doesn’t want to pay any higher income taxes than necessary.

At Kalispell, Montana, in 1955, he acquired initially ten acres of land for $2500. Then he and Mrs. Peterson set up a commercial corporation called Glacier Memorial Gardens of Kalispell, Inc. The two Petersons received the only stock is sued by the company for a total purchase price of $60.

A month after the acquisition of the land, it was deeded to the new corporation. Simultaneously, there was executed a “land purchase and financing…

2Cases cited4 opinions

  1. Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
  2. Knollwood Memorial Gardens v. CommissionerUnited States Tax Court · 1966
  3. Sherwood Memorial Gardens, Inc., (Tennessee) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
  4. GARDENS OF FAITH, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, RespondentCourt of Appeals for the Fourth Circuit · 1965

3Cited by5 opinions

  1. Rudolph A. Hardman, Frances N. Hardman and Hardman, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1987
  2. Rose Hills Memorial Park Ass'n v. United StatesUnited States Court of Claims · 1972
  3. Gyro Engineering Corp. v. United StatesDistrict Court, C.D. California · 1967
  4. National Labor Relations Board v. Kayser-Roth Hosiery Co., Inc.Court of Appeals for the Fourth Circuit · 1968
  5. Rose Hills Memorial Park Ass'n v. United StatesUnited States Court of Claims · 1972

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