Merrill N. Bradley and John R. Murray v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• applying the Danielson rule where taxpayer executed a sale agreement and later attempted to argue that the transaction was not “sale” but an “option” agreement
• applying the Danielson rule where taxpayer executed a sale agreement and later attempted to argue that the transaction was not “sale” but an “option” agreement
• affirming a District Court holding that payments received were interest income pursuant to a sale rather than an option to purchase because the contract called for interest payments
• whether funds received from real property purchaser were interest income or payments on a continuing option
• “It is well settled law that the Commissioner of the Internal Revenue Service, in determining income tax liabilities, may look through the form of a transaction to its substance.”

Source: CourtListener parenthetical corpus (CC0).