RERI Holdings I, LLC v. Comm'r
United States Tax Court
PS, a partnership, paid $2.95 million in March 2002 to acquire a remainder interest in property. The agreement that created the remainder interest provided covenants intended to preserve the value of the subject property but also limited the remedy available to the holder of the remainder interest for a breach of those covenants to immediate possession of the property; in no event would the holder of the corresponding term interest be liable for damages to the holder of the…
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PS, a partnership, paid $2.95 million in March 2002 to acquire a remainder interest in property. The agreement that created the remainder interest provided covenants intended to preserve the value of the subject property but also limited the remedy available to the holder of the remainder interest for a breach of those covenants to immediate possession of the property; in no event would the holder of the corresponding term interest be liable for damages to the holder of the remainder interest. On Aug. 27, 2003, PS assigned the remainder interest to U, a university. On its 2003 Form 1065, U.S.…
1Opinion of the Court
RERI HOLDINGS I, LLC, JEFF BLAU, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
RERI Holdings I, LLC v. Comm'r
Docket No. 9324-08
United States Tax Court
2017 U.S. Tax Ct. LEXIS 33; 149 T.C. No. 1;
July 3, 2017, Filed
Reri Holdings I, LLC v. Comm'r, T.C. Memo 2014-99, 2014 Tax Ct. Memo LEXIS 100 (T.C., May 22, 2014)
Decision will be entered under Rule 155.
PS, a partnership, paid $2.95 million in March 2002 to acquire a remainder interest in property. The agreement that created the remainder interest provided covenants intended to preserve the value of the subject…
2Cases cited33 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Shea v. CommissionerUnited States Tax Court · 1999
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
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