Eggert v. Commissioner
United States Tax Court
Petitioners were in the business of subdividing property owned by them in Madison, Conn., constructing houses thereon, and selling the improved lots. In 1973, in order to obtain approval of their subdivision plan and building permits, petitioners were required by the Planning and Zoning Commission of Madison to convey to the Land Conservation Trust of Madison for public purposes, 3.64 acres of their property for no consideration.
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Petitioners were in the business of subdividing property owned by them in Madison, Conn., constructing houses thereon, and selling the improved lots. In 1973, in order to obtain approval of their subdivision plan and building permits, petitioners were required by the Planning and Zoning Commission of Madison to convey to the Land Conservation Trust of Madison for public purposes, 3.64 acres of their property for no consideration. Held, the conveyance of the land was in the nature of a capital outlay and petitioners were not entitled to deduct their basis therein as an ordinary and necessary…
1Opinion of the Court
WILLIAM H. EGGERT and PHYLLIS A. EGGERT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Eggert v. Commissioner
Docket No. 10549-75.
United States Tax Court
T.C. Memo 1977-265; 1977 Tax Ct. Memo LEXIS 177; 36 T.C.M. (CCH) 1071; T.C.M. (RIA) 770265;
August 11, 1977, Filed
Petitioners were in the business of subdividing property owned by them in Madison, Conn., constructing houses thereon, and selling the improved lots. In 1973, in order to obtain approval of their subdivision plan and building permits, petitioners were required by the Planning and Zoning Commission of Madison to convey…
2Cases cited13 opinions
- United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Norden-Ketay Corporation (Formerly Ketay Instrument Corporation) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Chicago & NWR Co. v. Commissioner of Internal Rev.Court of Appeals for the Seventh Circuit · 1940
- Florida Publishing Co. v. CommissionerUnited States Tax Court · 1975
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Oriole Homes Corp. v. United StatesDistrict Court, S.D. Florida · 1989