Dunnegan v. Commissioner
United States Tax Court
In 1985, P and his parents (Fs) acquired a rental property as tenants in common. As part of the purchase price, P and Fs incurred a $ 111,750 debt for which they were jointly and severally liable. On Aug. 30, 1988, P sold his principal residence for an adjusted sales price of $ 214,000. In Feb. 1990, P gave his interest in the rental property to Fs; P and Fs remained jointly and severally liable for the debt.
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In 1985, P and his parents (Fs) acquired a rental property as tenants in common. As part of the purchase price, P and Fs incurred a $ 111,750 debt for which they were jointly and severally liable. On Aug. 30, 1988, P sold his principal residence for an adjusted sales price of $ 214,000. In Feb. 1990, P gave his interest in the rental property to Fs; P and Fs remained jointly and severally liable for the debt. On July 31, 1990, P repurchased the rental property for $ 215,000 as his new principal residence under sec. 1034(a), I.R.C. P agreed with Fs to assume the $ 101,125 balance remaining on…
1Opinion of the Court
WILLIAM DUNNEGAN AND JACQUELINE FISHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dunnegan v. Commissioner
Docket No. 8428-94
United States Tax Court
T.C. Memo 1995-167; 1995 Tax Ct. Memo LEXIS 159; 69 T.C.M. (CCH) 2391;
April 11, 1995, Filed
Decision will be entered under Rule 155.
In 1985, P and his parents (Fs) acquired a rental property as tenants in common. As part of the purchase price, P and Fs incurred a $ 111,750 debt for which they were jointly and severally liable. On Aug. 30, 1988, P sold his principal residence for an adjusted sales price of $ 214,000. In Feb. 1990, P…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Antonides v. CommissionerUnited States Tax Court · 1988
- Dellacroce v. CommissionerUnited States Tax Court · 1984
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