Haag v. Commissioner
United States Tax Court
A corporation which had formerly leased its business property from a stockholder found it necessary to acquire title to the property in order to obtain a $ 150,000 loan. The property which had a fair market value of $ 72,000 was purchased for $ 52,000 of preferred stock and the assumption of a $ 20,000 mortgage.
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A corporation which had formerly leased its business property from a stockholder found it necessary to acquire title to the property in order to obtain a $ 150,000 loan. The property which had a fair market value of $ 72,000 was purchased for $ 52,000 of preferred stock and the assumption of a $ 20,000 mortgage. The stockholder was also given an option to repurchase after the loan was repaid for the same $ 72,000 price despite the fact that one of the conditions of the loan was that at least $ 70,000 be used for building construction, and in fact more than $ 92,000 was spent in additions to…
1Opinion of the Court
Hoyt, Judge:
The respondent determined deficiencies in petitioners’ income taxes for the years 1956,1957, and 1958, as follows:
Doclcet No. Year Amount
91191 - 1956 $338. 92
1957 110,313.88
1958 425.22
91192- 1956 6, 280. 94
1957 2,104. 56
1958 1, 205.93
As a result of concessions by both parties in the pleadings, at the trial, and on brief, most of the issues have been determined. The principal issue remaining for decision is whether the petitioners in Docket No. 91191 received taxable income in 1957 when they purchased property worth $150,000 from the E. B. Sewall Manufacturing Co. for $72,000. It…
2Cases cited13 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. SmithSupreme Court of the United States · 1945
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Court Holding Co. v. CommissionerUnited States Tax Court · 1943
8 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- William J. Haag and Edith C. Haag v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. E. B. Sewall Manufacturing CompanyCourt of Appeals for the Eighth Circuit · 1964
- Caracci v. Comm'rUnited States Tax Court · 2002
- Matthies v. Comm'rUnited States Tax Court · 2010
- Caracci v. Comm'rUnited States Tax Court · 2002
- Haag v. CommissionerUnited States Tax Court · 1963
6 more not listed; retrieve them via the Exa API.