Taylor v. Commissioner
United States Tax Court
Petitioners in computing their farm income, satisfied the accounting requirements of sec. 1251(b)(4)(A) but failed to make the elective statement pursuant to sec. 1251(b)(4)(B) and respondent's regulations. Held, petitioners have substantially complied with the requirements of and are entitled to the benefits conferred by sec. 1251(b)(4) by fulfilling all the essential requirements thereof.
1Opinion of the Court
OPINION
Sterrett, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for the calendar years 1970 and 1971 in the amounts of $7,434.60 and $7,438.35, respectively. The issue for decision is whether petitioners, due to their failure to file a statement of election with their returns, are deprived of the benefits of section 1251(b)(4), I.R.C. 1954.
All of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.
Petitioners Jaquelin E. Taylor and Helen M. Taylor,…
2Cases cited17 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Cary v. CommissionerUnited States Tax Court · 1963
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3Cited by83 opinions
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- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- Hewitt v. Comm'rUnited States Tax Court · 1997
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