Brown v. Commissioner
United States Tax Court
1. Petitioner corporation acquired assets from a partnership pursuant to an installment sales contract under the terms of which the consideration was to be paid in 10 equal annual installments. Title to the assets was reserved in the partners until the full purchase price was paid.
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1. Petitioner corporation acquired assets from a partnership pursuant to an installment sales contract under the terms of which the consideration was to be paid in 10 equal annual installments. Title to the assets was reserved in the partners until the full purchase price was paid. Held, the sales contract was not stock or securities within the meaning of section 112 (b) (5), I. R. C. 1939, and the gain realized by the transferors on the transaction was recognized. 2. Held, further, the basis to the transferee corporation of the assets acquired by it is the cost of the assets. Sec. 113 (a),…
1Opinion of the Court
Warren H. Brown, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Brown v. Commissioner
Docket Nos. 50179, 50180, 50181, 50182, 50183
United States Tax Court
27 T.C. 27; 1956 U.S. Tax Ct. LEXIS 67; 27 T.C. No. 3;
October 18, 1956, Filed
Decisions will be entered under Rule 50.
1. Petitioner corporation acquired assets from a partnership pursuant to an installment sales contract under the terms of which the consideration was to be paid in 10 equal annual installments. Title to the assets was reserved in the partners until the full purchase price was paid. Held, the sales…
2Cases cited10 opinions
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Camp Wolters Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- Brown v. CommissionerUnited States Tax Court · 1956
- Camp Wolters Enterprises, Inc. v. CommissionerUnited States Tax Court · 1954
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