Crenshaw v. United States

450 F.2d 472 (1971)

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Crenshaw v. United States

United States Court of Appeals for the Fifth Circuit
450 F.2d 472 (1971)

Facts

Frances Wood Wilson (plaintiff) owned an undivided 50/225 interest in Pine Forest Associates, a partnership. Leon Blair, who owned the remaining interests along with his wife, sought to acquire Wilson’s interest. Wilson and Blair agreed that Wilson would exchange her interest for income-producing property, which had been owned by her recently deceased husband, rather than cash. Wilson withdrew from the partnership in exchange for a 50/225 interest in the Pine Forest Apartments, which was owned by the partnership. Acting individually and as executrix of her husband’s estate, Wilson then exchanged her interest in the Pine Forest Apartments for other property—a shopping center—belonging to the estate. Then, acting solely as executrix, Wilson transferred the estate’s interest in the Pine Forest Apartments to Blair’s closely held corporation, the Blair Investment Company, for $200,000. The Blair Investment Company transferred its 50/225 interest in the Pine Forest Apartments to the partnership in exchange for the 50/225 partnership interest formerly owned by Wilson. The Commissioner of Internal Revenue deemed this series of steps a taxable sale and assessed a deficiency. Wilson challenged the deficiency in federal district court. The court granted summary judgment in favor of Wilson. The United States government (defendant) appealed. The United States Court of Appeals for the Fifth Circuit granted certiorari. At some point during the proceedings, Wilson died. Emory Crenshaw (plaintiff) acted as the executor of Wilson’s estate.

Rule of Law

Issue

Holding and Reasoning (Brown, C.J.)

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