Adams v. Commissioner
United States Tax Court
Petitioner Robert W. Adams in two related transactions first transferred all of his equity interest in Two States Uranium Corp. to Wyoming Mining & Milling Co. in exchange for Wyoming stock. Next, he sold a valuable mining claim to Wyoming and received in exchange Wyoming's note for $ 1 million. Wyoming then built a device to concentrate uranium ore at the mine site and leased the mining property and preconcentrator to Western for royalties and rent.
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Petitioner Robert W. Adams in two related transactions first transferred all of his equity interest in Two States Uranium Corp. to Wyoming Mining & Milling Co. in exchange for Wyoming stock. Next, he sold a valuable mining claim to Wyoming and received in exchange Wyoming's note for $ 1 million. Wyoming then built a device to concentrate uranium ore at the mine site and leased the mining property and preconcentrator to Western for royalties and rent. Western advanced Wyoming $ 940,000 on the lease and Wyoming used this sum to complete payment of the note to petitioner. Before the advance…
1Opinion of the Court
Robert W. Adams and Eleanor Adams Corson (Formerly Eleanor C. Adams), et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Adams v. Commissioner
Docket Nos. 5461-68, 5462-68, 5463-68
United States Tax Court
58 T.C. 41; 1972 U.S. Tax Ct. LEXIS 146; 58 T.C. No. 4;
April 17, 1972, Filed
Decisions will be entered under Rule 50.
Petitioner Robert W. Adams in two related transactions first transferred all of his equity interest in Two States Uranium Corp. to Wyoming Mining & Milling Co. in exchange for Wyoming stock. Next, he sold a valuable mining claim to Wyoming and received in…
2Cases cited46 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Crane v. CommissionerSupreme Court of the United States · 1947
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Anderson v. HelveringSupreme Court of the United States · 1940
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
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