Rutherford v. Commissioner
United States Tax Court
T.C. Memo. 1978-505
- Written by Heather Whittemore, JD
Facts
Bennie Rutherford (plaintiff) was a farmer who raised cattle. Rutherford entered into an agreement with Wardlow. Wardlow would give 12 half-blood cows to Rutherford, and in exchange, Rutherford would breed the cows with a registered bull and give Wardlow the first 12 three-quarter-blood cows. Wardlow delivered the 12 half-blood cows to Rutherford, and Rutherford delivered the 12 three-quarter-blood cows to Wardlow over the course of three years. Rutherford deducted the cost of producing the cows as expenses on his income-tax returns for those three years and argued that his basis was the fair market value of the half-blood cows. The Commissioner of Internal Revenue (the Commissioner) (defendant) argued that Rutherford had no basis in the half-blood cows because they were paid for through the exchange of property under § 1031 of the Internal Revenue Code. Rutherford petitioned the United States Tax Court for a redetermination.
Rule of Law
Issue
Holding and Reasoning (Tannenwald, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
