U.S. Court of Appeals for the Ninth Circuit, 1974

A. W. And Williamena Legg v. Commissioner of Internal Revenue

U.S. Court of Appeals for the Ninth Circuit · Decided May 15, 1974 · Koelsch, Wallace, Skopil

496 F.2d 1179; 33 A.F.T.R.2d (RIA) 74 (Federal Reporter, Second Series)

Counsel

William C. Ruthford (argued), Jones, Grey, Bayley & Olsen, Seattle, Wash., for petitioners-appellants., David English Carmack (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., U. S. Dept, of Justice, Washington, D. C., Lee H. Henkel, Jr., Acting Chief Counsel, IRS, Washington, D. C., Richard J. Shipley, Seattle, Wash., for respondent-appellee.

Cases that cite this one

15 later published cases cite this decision.

Estate of Durkin v. Commissioner (United States Tax Court 1992)
Norwest Corp. v. Comm'r (United States Tax Court 1998)
Estate of Leon Israel, Jr., Barry W. Gray, and Audrey H. Israel v. Commissioner (United States Tax Court 1997)
Friendly Finance, Inc. v. Commissioner (United States Tax Court 1991)
Church of Scientology v. Commissioner (United States Tax Court 1984)
Hoover Co. v. Commissioner (United States Tax Court 1979)
La Fargue v. Commissioner (United States Tax Court 1979)
The Coca-Cola Company and Subsidiaries v. Commissioner (United States Tax Court 2020)
Klaas v. Comm'r (United States Tax Court 2009)
In re Forte (United States Bankruptcy Court, E.D. New York 1999)
Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries v. Commissioner (United States Tax Court 1998)
Matz v. Commissioner (United States Tax Court 1998)
Jolin v. Commissioner (United States Tax Court 1985)
Williams Home, Inc. v. United States (District Court, W.D. Virginia 1982)
Rochester Development Corp. v. Commissioner (United States Tax Court 1977)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

OPINION

PER CURIAM:

The Tax Court, concluding that taxpayers’ transfer of their vendors’ interest in an installment contract to an irrevocable trust constituted a disposition within the purview of 26 U.S.C. § 453(d) and thus subjected the gain to immediate recognition, affirmed the Commissioner’s determination of deficiencies in their income tax. 57 T.C. 164.

A review of the record discloses that all factual determinations are supported by the evidence, that the relevant statutory provisions were properly construed and applied, and that the rationale of the Tax Court was correct and ought to be approved.

Affirmed.

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