Barenholtz v. Commissioner
United States Tax Court
P agreed to sell undivided one-fourth interests in real property to each of three individuals with whom he intended to form a partnership for the operation of the property. Thereafter, the partnership was formed, the interests were sold, and title to the property was transferred to the partnership. Held, the transaction was not within the purview of secs. 721 and 731, I.R.C. 1954, but was a sale by P of 75 percent of his interest in the property.
1Opinion of the Court
Jonas Barenholtz and Aubrey Barenholtz, Petitioners v. Commissioner of Internal Revenue, Respondent
Barenholtz v. Commissioner
Docket No. 12250-78
United States Tax Court
77 T.C. 85; 1981 U.S. Tax Ct. LEXIS 97;
July 23, 1981, Filed
Decision will be entered for the respondent.
P agreed to sell undivided one-fourth interests in real property to each of three individuals with whom he intended to form a partnership for the operation of the property. Thereafter, the partnership was formed, the interests were sold, and title to the property was transferred to the partnership. Held, the transaction was not…
2Cases cited4 opinions
- Foxman v. CommissionerUnited States Tax Court · 1964
- Otey v. CommissionerUnited States Tax Court · 1978
- John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Barenholtz v. CommissionerUnited States Tax Court · 1981