Legal Opinion

Dellinger v. Commissioner

United States Tax Court

Decided September 14, 1959No. Docket No. 72838Published

Petitioner, in the taxable year 1954, purchased three vacant lots from a corporation, in which he held a one-third stock interest, at prices representing cost or less to said corporation.

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Petitioner, in the taxable year 1954, purchased three vacant lots from a corporation, in which he held a one-third stock interest, at prices representing cost or less to said corporation. The corporation was engaged in selling lots in a new land development to the public at large and commenced business in April 1953. The lowest price which the corporation has accepted for any lots in the subdivision, other than from a shareholder, was $ 1,800. One of the lots which petitioner purchased as an investment for $ 250 (below cost to the corporation) was sold 7 months later for $ 2,445. Each time a…

1Opinion of the Court

Lester E. Dellinger and Anne R. Dellinger, Petitioners v. Commissioner of Internal Revenue, Respondent

Dellinger v. Commissioner

Docket No. 72838

United States Tax Court

32 T.C. 1178; 1959 U.S. Tax Ct. LEXIS 90;

September 14, 1959, Filed

Decision will be entered under Rule 50.

Petitioner, in the taxable year 1954, purchased three vacant lots from a corporation, in which he held a one-third stock interest, at prices representing cost or less to said corporation. The corporation was engaged in selling lots in a new land development to the public at large and commenced business in April 1953. The…

2Cases cited15 opinions

  1. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  2. Palmer v. CommissionerSupreme Court of the United States · 1937
  3. Paramount-Richards Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
  4. Lincoln Nat. Bank v. BurnetCourt of Appeals for the D.C. Circuit · 1933
  5. Dellinger v. CommissionerUnited States Tax Court · 1959

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