Steckel v. Commissioner
United States Tax Court
Certain attorneys rendered services for decedent prior to 1941, and in 1948 they obtained a judgment against decedent for the value of their services plus expenses. In 1945 decedent had disposed of his stock in a corporation, and in 1949 he became entitled to a partial payment for this stock. The court ordered that $ 225,000 of the amount to which decedent was entitled be paid to the clerk of the court as security pending decedent's appeal of the judgment for the attorneys.
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Certain attorneys rendered services for decedent prior to 1941, and in 1948 they obtained a judgment against decedent for the value of their services plus expenses. In 1945 decedent had disposed of his stock in a corporation, and in 1949 he became entitled to a partial payment for this stock. The court ordered that $ 225,000 of the amount to which decedent was entitled be paid to the clerk of the court as security pending decedent's appeal of the judgment for the attorneys. The judgment was affirmed, and in 1951 the sum of $ 190,355.82 was paid to the attorneys in satisfaction of their…
1Opinion of the Court
OPINION.
BRUCE, Judge:
The question is the amount of long-term capital gain realized by Steckel in 1949. In 1945 Steckel transferred his stock in the Cold Metal Process Company to another stockholder, the Union National Bank of Youngstown, Ohio, trustee of the Leon A. Beeghly Fund. The trustee was to pay for the stock when and if it received certain funds. In 1949 the trustee received a portion of the funds mentioned and was ready to make a partial payment for the stock. However, it was prevented from making a payment to Steckel by an order of the District Court in aid of execution of a…
2Cases cited17 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Lykes v. United StatesSupreme Court of the United States · 1952
- Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
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3Cited by1 opinion
- Steckel v. CommissionerUnited States Tax Court · 1956