Legal Opinion
John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided November 25, 1980No. 79-1183PublishedCited by 19 opinions
1Per curiam
The question in this case is whether the transfer of real estate by a partner, John H. Otey, Jr., to a partnership in which he had a 50% interest, Court Villa Apartments, was a sale or a contribution of capital. The Tax Court held that the transaction effected a contribution of capital, and the Commissioner appeals.
The facts surrounding the transaction were stipulated as follows:
On October 19, 1971, Petitioner (Otey) and Marion Thurman entered into a Joint Venture Agreement for the purpose of developing a 221(d)(4) residential apartment project at 2612-14 Heiman Street, Nashville, Tennessee.
In…
2Cited by19 opinions
- Colonnade Condominium, Inc. v. CommissionerUnited States Tax Court · 1988
- Jupiter Corp. v. United StatesUnited States Court of Claims · 1983
- Barenholtz v. CommissionerUnited States Tax Court · 1981
- Richard O. Jacobson, Cheryl H. Jacobson, Lawrence E. Larson, and Donna C. Larson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1992
- Communications Satellite Corp. v. United StatesUnited States Court of Claims · 1980
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