Blick v. Commissioner
United States Tax Court
Petitioner held options or contracts to purchase four parcels of real property. Each was in form a contract of purchase and sale, but petitioner's liability was limited to retention by the seller of the deposit. A corporation desired to buy the properties under contract plus certain adjoining parcels, but only if all could be acquired.
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Petitioner held options or contracts to purchase four parcels of real property. Each was in form a contract of purchase and sale, but petitioner's liability was limited to retention by the seller of the deposit. A corporation desired to buy the properties under contract plus certain adjoining parcels, but only if all could be acquired. A contract was entered into whereby petitioner agreed to sell and the corporation agreed to purchase all of the desired tracts at a stated overall price. Petitioner then acquired options or contracts to purchase covering the other parcels. All conveyances were…
1Opinion of the Court
Forrester, Judge:
Respondent has determined a deficiency in the income tax of petitioners for their taxable year 1951 in the amount of $26,657.18. The issue is whether respondent erred in disallowing to a certain gain realized by petitioners the treatment provided in section 117 (b) of the Internal Revenue Code of 1939.1
FINDINGS OF FACT.
Petitioners, husband and wife, reside in Elizabeth, New Jersey. Their return for the taxable year 1951 was filed with the director of internal revenue at Newark, New Jersey. Anne Blick did not actively participate in any pertinent transaction, and the…
2Cases cited4 opinions
- Max H. Barber v. United States of America, William L. Taylor v. United StatesCourt of Appeals for the Eighth Circuit · 1954
- Sooy v. HenkelmanSupreme Court of New Jersey · 1928
- Hildinger v. BishopNew Jersey Court of Chancery · 1939
- Clusman v. Wall-Murray Corp.Supreme Court of New Jersey · 1943
3Cited by14 opinions
- William W. Saunders and Gertrude H. Saunders v. United StatesCourt of Appeals for the Ninth Circuit · 1971
- Louis D. Blick and Anne Blick v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Anders v. CommissionerUnited States Tax Court · 1977
- Fraser v. CommissionerUnited States Tax Court · 1975
- Chemetron Corporation, a Delaware Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
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