# Ragland Inv. Co. v. Commissioner > United States Tax Court · August 26, 1969 · 52 T.C. 867 URL: https://www.frixlaw.com/law-library/cases/4481324 ## Case - **Full name:** Ragland Investment Company, 1 v. Commissioner of Internal Revenue - **Court:** United States Tax Court - **Decided:** August 26, 1969 - **Citations:** 52 T.C. 867; 1969 U.S. Tax Ct. LEXIS 69 - **Precedential status:** Published - **Opinion:** Dissent by Simpson - **Judges:** Sterrett,Hoyt,Tietjens,Raum,Dawson,Hoyt,Simpson,Tietjens,Dawson,Hoyt - **Cited by:** 1 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4481324 ## Opinion text Simpson, J., dissenting: I agree with Judge Tietjens’ conclusion, but as the author of the opinion in Zilkha & Sons, Inc., 52 T.C. 607 (1969), I wish to add my comments. Based on the facts of this case, I would conclude that the securities acquired by the sellers in substance more resembled a debt than stock. In selling the businesses, the sellers were willing to agree to defer part of the purchase price. However, they wanted to receive earnings on the deferred part of the purchase price, and they wanted to receive full payment within a relatively short time — 4 years. As a result of the agreement made with the shareholders of the purchaser, the sellers were assured that they would receive the desired earnings and the desired repayment. They did not assume the risks of a shareholder. Compare Zilkha & Sons, Inc., supra. Tietjens, Dawson, and Hoyt, JJ., agree with this dissent. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4481324. Public record. Not legal advice.