Legal Opinion

Redwood Empire Sav. & Loan Asso. v. Commissioner

United States Tax Court

Decided July 8, 1985No. Docket Nos. 11948-77, 11949-77, 11950-77Unpublished

P, a California savings and loan association, purchased unimproved real property in 1962. At the time of purchase, P entered into a take-out loan commitment and repurchase agreement with D. D defaulted on his obligations. In 1964 P transferred the property to G for $265,000 and then reacquired the property from G for $175,725.50 in 1965. P sold the property to the State of California for $55,349 in 1974 and claimed an ordinary loss on the sale.

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P, a California savings and loan association, purchased unimproved real property in 1962. At the time of purchase, P entered into a take-out loan commitment and repurchase agreement with D. D defaulted on his obligations. In 1964 P transferred the property to G for $265,000 and then reacquired the property from G for $175,725.50 in 1965. P sold the property to the State of California for $55,349 in 1974 and claimed an ordinary loss on the sale. R determined the loss to be a capital loss. Held, property sold by P was not property held for sale to customers in the ordinary course of P's…

1Opinion of the Court

REDWOOD EMPIRE SAVINGS AND LOAN ASSOCIATION, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Redwood Empire Sav. & Loan Asso. v. Commissioner

Docket Nos. 11948-77, 11949-77, 11950-77.

United States Tax Court

T.C. Memo 1985-332; 1985 Tax Ct. Memo LEXIS 300; 50 T.C.M. (CCH) 345; T.C.M. (RIA) 85332;

July 8, 1985.

P, a California savings and loan association, purchased unimproved real property in 1962. At the time of purchase, P entered into a take-out loan commitment and repurchase agreement with D. D defaulted on his obligations. In 1964 P transferred the property to G for…

2Cases cited15 opinions

  1. Higgins v. CommissionerSupreme Court of the United States · 1941
  2. Commissioner v. BrownSupreme Court of the United States · 1965
  3. Malat v. RiddellSupreme Court of the United States · 1966
  4. Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
  5. Haggard v. CommissionerUnited States Tax Court · 1955

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