Herzog Bldg. Corp. v. Commissioner
United States Tax Court
1. Before approving petitioner's subdivision plan or issuing building permits, the village required provision for an adequate sewerage system. To make possible the development of its property, petitioner agreed to buy sewerage revenue bonds, so that the village could build such a system. Petitioner did not desire to invest in sewerage revenue bonds.
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1. Before approving petitioner's subdivision plan or issuing building permits, the village required provision for an adequate sewerage system. To make possible the development of its property, petitioner agreed to buy sewerage revenue bonds, so that the village could build such a system. Petitioner did not desire to invest in sewerage revenue bonds. Held, the amount which petitioner agreed to pay for the bonds was properly allocated to the cost basis of land. 2. An amount which petitioner estimated it would become obligated to pay under an agreement to reimburse a related company for the…
1Opinion of the Court
Forrester, Judge:
The respondent has determined deficiencies in petitioner’s income taxes for the calendar years 1955 and 1956 in the respective amounts of $63,821.98 and $117,233.44. The issues to be decided are (1) whether petitioner may deduct any part of an amount it agreed to pay for sewerage revenue bonds by allocating a part of such amount to its cost of lots sold to home buyers in 1955 and 1956; (2) whether petitioner may, by a similar procedure, deduct part of an amount it estimated it would become obligated to pay, under an oral agreement, as reimbursement to a related company for…
2Cases cited14 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Albert Gersten, Myron P. Beck and Ann H. Beck, Milton Gersten and Mary Gersten v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Eline Realty Co. v. CommissionerUnited States Tax Court · 1960
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- The Colony, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Greene v. CommissionerUnited States Tax Court · 1983
- Westchester Dev. Co. v. CommissionerUnited States Tax Court · 1974
- United States v. Robert R. KrilichCourt of Appeals for the Seventh Circuit · 1972
- Derby Heights, Inc. v. CommissionerUnited States Tax Court · 1967
- Haynsworth v. CommissionerUnited States Tax Court · 1977
17 more not listed; retrieve them via the Exa API.