This section contains the nature of the case and procedural background.

Crichton’s (P) children transferred interests in real property. P and her three children, owned, in undivided interests, a tract of unimproved country land and an improved city lot. The children transferred to P their undivided interest in the city lot. P transferred to her children, as of equal value, an undivided 3/12 interest in the 'oil, gas and other minerals, in, on and under, and that may be produced from' the country land. The 1/2 interest conveyed to P had a value of $15,357.77. The interest P transferred to her children had a cost basis of zero. P treated the exchange as property for property and did not report the profit therefrom. The IRS contended that P had made a gain of the $15,357.77 and assessed her based on that amount. The Board found that the exchange was solely in kind and reduced the tax assessment substantially.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.