Home/Ninth Circuit/A. W. And Williamena Legg v. Commissioner of Internal Revenue

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

496 F.2d 1179, 33 A.F.T.R.2d (RIA) 74
CourtCourt of Appeals for the Ninth Circuit
DecidedMay 15, 1974
Docket72-2233
StatusPublished
Cited by27 cases

This text of 496 F.2d 1179 (A. W. And Williamena Legg v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A. W. And Williamena Legg v. Commissioner of Internal Revenue, 496 F.2d 1179, 33 A.F.T.R.2d (RIA) 74 (9th Cir. 1974).

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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Bluebook (online)
496 F.2d 1179, 33 A.F.T.R.2d (RIA) 74, Counsel Stack Legal Research, https://law.counselstack.com/opinion/a-w-and-williamena-legg-v-commissioner-of-internal-revenue-ca9-1974.