Foy v. Commissioner
United States Tax Court
Petitioners sold their contract rights in a janitorial and building maintenance franchise network and reported the proceeds of the sale under the installment method of accounting. Held, petitioners sold capital assets which are entitled to capital gain treatment. Held, further, the proceeds properly were reported under the installment method.
1Opinion of the Court
James E. Foy and Nancy L. Foy, Petitioners v. Commissioner of Internal Revenue, Respondent; Expansion Enterprises, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Foy v. Commissioner
Docket Nos. 10976-81, 10977-81
United States Tax Court
84 T.C. 50; 1985 U.S. Tax Ct. LEXIS 135; 84 T.C. No. 4;
January 14, 1985. January 14, 1985, Filed
Decision will be entered for the petitioners in docket No. 10976-81.
Decision will be entered under Rule 155 in docket No. 10977-81.
Petitioners sold their contract rights in a janitorial and building maintenance franchise network and reported the…
2Cases cited18 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
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