Estate of Wilson v. Commissioner

Fifth Circuit

Estate of Wilson v. Commissioner

255 F.2d 702

Court of Appeals for the Fifth Circuit·Decided May 29, 1958·No. No. 16923·Published

Opinion

PER CURIAM.

The executors of Sam E. Wilson, Jr., here challenge the correctness of a determination of his Federal income tax liability for 1948 as made by the Tax Court. Its opinion is reported in 27 T.C. 976. We are in accord with the Tax Court’s conclusions. Had the taxpayer adopted a different form for the particular transaction the tax incident might have been different. Cf. Zenz v. Quinlivan, 6 Cir., [703]*7031954, 213 F.2d 914. The difference in the factual situation makes Mayer v. Don-nelly, 5 Cir., 1957, 247 F.2d 322, inapplicable. For the reasons assigned by the Tax Court in its opinion its judgment is

Affirmed.

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PER CURIAM.

The executors of Sam E. Wilson, Jr., here challenge the correctness of a determination of his Federal income tax liability for 1948 as made by the Tax Court. Its opinion is reported in 27 T.C. 976. We are in accord with the Tax Court’s conclusions. Had the taxpayer adopted a different form for the particular transaction the tax incident might have been different. Cf. Zenz v. Quinlivan, 6 Cir., [703]*7031954, 213 F.2d 914. The difference in the factual situation makes Mayer v. Don-nelly, 5 Cir., 1957, 247 F.2d 322, inapplicable. For the reasons assigned by the Tax Court in its opinion its judgment is

Affirmed.

Estate of Wilson v. Commissioner, 255 F.2d 702 (5th Cir. 1958).

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Opinion

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