Berry v. Commissioner
United States Tax Court
The G.B.M. Co., a partnership comprised of petitioners and two other partners, sold the Raleigh Hotel located in Washington, D.C., on October 26, 1953, for a stated purchase price of $ 3,240,000. Sellers took back an 11-year note in the stated amount of $ 1,548,739.10. The contract recites the note is to be without interest, but includes a prepayment discount schedule.
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The G.B.M. Co., a partnership comprised of petitioners and two other partners, sold the Raleigh Hotel located in Washington, D.C., on October 26, 1953, for a stated purchase price of $ 3,240,000. Sellers took back an 11-year note in the stated amount of $ 1,548,739.10. The contract recites the note is to be without interest, but includes a prepayment discount schedule. Earlier offer to purchase made by the buyer contemplated a purchase price of $ 2,800,000 with the sellers taking back a note bearing interest at 4 1/2 percent for the deferred payments. The discount schedule included in both…
1Opinion of the Court
BRUCE, Judge:
Respondent, in his statutory notice of deficiency dated August 29, 1960, determined deficiencies in the income taxes of the petitioners for the years and in the amounts hereinafter set forth. By amendment to his answer filed in each of these proceedings, on April 8, 1964, in accordance with the provisions of section 6214(a) of the Internal Revenue Code of 1954, respondent claimed additional deficiencies for 2 of the 3 taxable years involved in each proceeding, based upon the opinion of this Court in Raleigh Properties, Inc., T.C. Memo. 1962-150. The deficiencies per statutory…
2Cases cited3 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Mills v. CommissionerUnited States Tax Court · 1948
- Elliott Paint & Varnish Co. v. CommissionerUnited States Board of Tax Appeals · 1941
3Cited by7 opinions
- Comtel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Paduano v. CommissionerUnited States Tax Court · 1975
- Estate of Berry v. CommissionerCourt of Appeals for the Sixth Circuit · 1967
- Estate of Betty Berry, Deceased, Louis Berry, Louis Berry, Surviving Spouse v. Commissioner of Internal Revenue, Lcg Trust No. 2, A. R. Glancy, Jr., Successor Trustee, Successor Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
- Estate of Bonnell v. CommissionerUnited States Tax Court · 1971
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