Legal Opinion

Camp Wolters Enterprises v. Commissioner

United States Tax Court

Decided June 30, 1954No. Docket No. 35561PublishedCited by 1 opinion

The Dennis Group purchased the Camp Wolters land (then under lease to the United States) along with restoration rights applicable to that land. It also concluded a "contract" with the United States to purchase the Camp Wolters buildings and improvements in return for $ 412,500 in cash and release of the restoration rights.

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The Dennis Group purchased the Camp Wolters land (then under lease to the United States) along with restoration rights applicable to that land. It also concluded a "contract" with the United States to purchase the Camp Wolters buildings and improvements in return for $ 412,500 in cash and release of the restoration rights. The group then formed petitioner, conveyed the land to petitioner for $ 151,336.88 in land notes, and assigned the "contract" and restoration rights to petitioner for $ 1,424 in cash and $ 411,080.20 in building notes. Petitioner paid the United States the $ 412,500,…

1Opinion of the Court

OPINION.

Black, Judge:

1. The major issue involves determining the correct basis of the buildings and improvements acquired from the Government by the petitioner. Respondent argues that their basis is composed only of the following:

Cash paid to the Government under the “contract” of purchase_$412, 500

Paid the Dennis Group’s nominee (Mims) for assignment of the

purchase “contract” and restoration rights_ 1,424

An unidentified and uncontested sum_ 2,350

$416,274

Petitioner, on the other hand, contends that included in that basis is an additional $411,080.20 given the Dennis Group (through Mims) in…

2Cases cited15 opinions

  1. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  2. MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
  3. Mauldin v. CommissionerUnited States Tax Court · 1951
  4. Helvering v. WattsSupreme Court of the United States · 1935
  5. Solt v. CommissionerUnited States Tax Court · 1952

10 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Camp Wolters Enterprises v. CommissionerUnited States Tax Court · 1954

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