Legal Opinion

Strandquist v. Commissioner

United States Tax Court

Decided April 13, 1970No. Docket No. 3654-66Unpublished

On the facts, held, (1) that the $125,000 paid by petitioner Albin Strandquist to his former wife Marjorie in 1960, pursuant to the terms of an agreement incident to a divorce, dated March 11, 1960, was solely for the purchase of her one-half interest in the Jan-Ann Breeding Farm; and, hence, petitioners correctly reported their long-term capital gain in the taxable year 1962 from the sale of the farm in March 1962 to the Sisters of Notre Dame De Namur.

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On the facts, held, (1) that the $125,000 paid by petitioner Albin Strandquist to his former wife Marjorie in 1960, pursuant to the terms of an agreement incident to a divorce, dated March 11, 1960, was solely for the purchase of her one-half interest in the Jan-Ann Breeding Farm; and, hence, petitioners correctly reported their long-term capital gain in the taxable year 1962 from the sale of the farm in March 1962 to the Sisters of Notre Dame De Namur. Held further, that petitioners are entitled to a deduction for depreciation of the assets of the farm during the taxable years 1961 and 1962…

1Opinion of the Court

Albin J. Strandquist and Carol E. Strandquist v. Commissioner.

Strandquist v. Commissioner

Docket No. 3654-66.

United States Tax Court

T.C. Memo 1970-84; 1970 Tax Ct. Memo LEXIS 277; 29 T.C.M. (CCH) 387; T.C.M. (RIA) 70084;

April 13, 1970, Filed

On the facts, held, (1) that the $125,000 paid by petitioner Albin Strandquist to his former wife Marjorie in 1960, pursuant to the terms of an agreement incident to a divorce, dated March 11, 1960, was solely for the purchase of her one-half interest in the Jan-Ann Breeding Farm; and, hence, petitioners correctly reported their long-term capital gain in…

2Cases cited31 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Commissioner v. DubersteinSupreme Court of the United States · 1960
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Commissioner v. LoBueSupreme Court of the United States · 1956

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