Legal Opinion

Lemmen v. Commissioner

United States Tax Court

Decided December 23, 1981No. Docket No. 1432-79Published

Petitioner Gerrit B. Lemmen purchased a herd of cattle in 1973 for a stated price of $ 40,000 and a second herd of cattle in 1974 for a stated price of $ 20,000. At the time of these purchases, the fair market value of the cattle was $ 7,000 per herd.

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Petitioner Gerrit B. Lemmen purchased a herd of cattle in 1973 for a stated price of $ 40,000 and a second herd of cattle in 1974 for a stated price of $ 20,000. At the time of these purchases, the fair market value of the cattle was $ 7,000 per herd. In connection with each purchase, petitioner entered into a maintenance contract under which the seller agreed to breed and otherwise care for the cattle in exchange for some of the heifer calves and all of the bull calves to be born during the term of the contract. Petitioner did not expect to realize any income from his cattle-breeding…

1Opinion of the Court

Gerrit B. Lemmen and Judith K. Lemmen, Petitioners v. Commissioner of Internal Revenue, Respondent

Lemmen v. Commissioner

Docket No. 1432-79

United States Tax Court

77 T.C. 1326; 1981 U.S. Tax Ct. LEXIS 5;

December 23, 1981, Filed

Decision will be entered under Rule 155.

Petitioner Gerrit B. Lemmen purchased a herd of cattle in 1973 for a stated price of $ 40,000 and a second herd of cattle in 1974 for a stated price of $ 20,000. At the time of these purchases, the fair market value of the cattle was $ 7,000 per herd. In connection with each purchase, petitioner entered into a maintenance contract…

2Cases cited24 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Engdahl v. CommissionerUnited States Tax Court · 1979
  4. Jasionowski v. CommissionerUnited States Tax Court · 1976
  5. Allen v. CommissionerUnited States Tax Court · 1979

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