Edwards v. Commissioner
United States Tax Court
In 1962, petitioners purchased stock and notes of a corporation for $ 75,000. The purchase contract allocated $ 5,000 to the stock and $ 70,000 to the notes. Held, amounts received by petitioners from the corporation on the principal of the notes did not constitute amounts received in exchange for such notes under sec. 1232(a), I.R.C. 1954.
1Opinion of the Court
TanNenwald, Judge:
Respondent determined deficiencies in petitioners’ joint income taxes as follows:
R. M. EDWARDS AM DOROTHY EDWARDS
(docket No. 2369-66)
Year Deficiency
1962_$3, 375. 68
1963_ 11,968.08
1964_ 5, 714. 48
Loyd W. Disler and Joy Disler
(docket No. 2388-66)
Year Deficiency
1962_$3,010.00
1963_ 11, 436. 23
1964_ 5, 375. 43
Both dockets were consolidated for trial and decision. Petitioners having conceded certain adjustments made by respondent, the sole issue remaining for decision is whether amounts received by petitioners on the principal of alleged corporate promissory notes are amounts…
2Cases cited11 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
6 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- R. M. Edwards and Dorothy Edwards v. Commissioner of Internal Revenue, Loyd W. Disler and Joy Disler v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1969
- Ardela, Inc. v. CommissionerUnited States Tax Court · 1969
- Imperial Car Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1970
- Snyder Bros. Co. v. CommissionerUnited States Tax Court · 1980
- Adams v. CommissionerUnited States Tax Court · 1978
7 more not listed; retrieve them via the Exa API.