§920

DFM Investment Company, Petitioner 108 T.C. No. 22 · 1997

sely resembles, upon notification of the purchaser's election to cancel the contract, the Dealership immediately becomes personally indebted to the purchaser for the amount of the unearned portion of the contract price. See 7 Williston on Contracts, sec. 920, at 618-619, 634 (3d ed. 1963). When the Dealership secures release of reserves - 30 - and uses them to discharge its personal indebtedness, it has plainly "received" them for purposes of the all events test. This result is consistent with t

David F. & Barbara J. Mungenast, Petitioner 108 T.C. No. 22 · 1997

sely resembles, upon notification of the purchaser's election to cancel the contract, the Dealership immediately becomes personally indebted to the purchaser for the amount of the unearned portion of the contract price. See 7 Williston on Contracts, sec. 920, at 618-619, 634 (3d ed. 1963). When the Dealership secures release of reserves - 30 - and uses them to discharge its personal indebtedness, it has plainly "received" them for purposes of the all events test. This result is consistent with t

Rameau A. & Phyllis A. Johnson, Petitioner 108 T.C. No. 22 · 1997

sely resembles, upon notification of the purchaser's election to cancel the contract, the Dealership immediately becomes personally indebted to the purchaser for the amount of the unearned portion of the contract price. See 7 Williston on Contracts, sec. 920, at 618-619, 634 (3d ed. 1963). When the Dealership secures release of reserves - 30 - and uses them to discharge its personal indebtedness, it has plainly "received" them for purposes of the all events test. This result is consistent with t

Haddad Motor Group, Inc. v. Karp, Ackerman, Skabowski & Hogan, P.V. 603 F.3d 1 · Cir.

Johnson v. Commissioner 108 T.C. 448 · 1997

United States v. Evelyn Johnson 911 F.3d 849 · Cir.

United States v. Evelyn Johnson · Cir.

8 Citing Cases

New cases, delivered.