Hilton v. Commissioner
United States Tax Court
Where the purchaser of a $ 175,000 note received as a part of the entire transaction a payment of $ 75,000 on the note, arranged for by the seller, and the purchaser intended to buy only $ 100,000 of the note, held, there was in substance a payment of $ 75,000 on the note by the maker to the seller; held, further, there was a bona fide sale of a capital asset to the extent of $ 100,000; held, further, a prior settlement agreement by the Commissioner of Internal Revenue and…
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Where the purchaser of a $ 175,000 note received as a part of the entire transaction a payment of $ 75,000 on the note, arranged for by the seller, and the purchaser intended to buy only $ 100,000 of the note, held, there was in substance a payment of $ 75,000 on the note by the maker to the seller; held, further, there was a bona fide sale of a capital asset to the extent of $ 100,000; held, further, a prior settlement agreement by the Commissioner of Internal Revenue and the taxpayer providing for the treatment of future payments on the note as ordinary income does not estop petitioners…
1Opinion of the Court
Conrad N. Hilton and Sari G. Hilton, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hilton v. Commissioner
Docket No. 18287
United States Tax Court
13 T.C. 623; 1949 U.S. Tax Ct. LEXIS 57;
October 24, 1949, Promulgated
Decision will be entered under Rule 50.
Where the purchaser of a $ 175,000 note received as a part of the entire transaction a payment of $ 75,000 on the note, arranged for by the seller, and the purchaser intended to buy only $ 100,000 of the note, held, there was in substance a payment of $ 75,000 on the note by the maker to the seller; held, further, there was a bona…
2Cases cited8 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Hobby v. CommissionerUnited States Tax Court · 1943
3 more not listed; retrieve them via the Exa API.