Raleigh Properties, Inc. v. Commissioner
United States Tax Court
Petitioner purchased a hotel in 1953 for a stated purchase price of $3,240,000. Sellers took back an 11-year note in the stated amount of $1,548,739.10. The contract recites that the note is to be without interest, but it includes a prepayment discount schedule.
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Petitioner purchased a hotel in 1953 for a stated purchase price of $3,240,000. Sellers took back an 11-year note in the stated amount of $1,548,739.10. The contract recites that the note is to be without interest, but it includes a prepayment discount schedule. Earlier negotiations contemplated a purchase price of $2,800,000, with the sellers taking back a note bearing interest at 4 1/2 percent for 11 years in an amount approximately $440,000 less than the note finally given by petitioner. The discount schedule closely paralleled the interest which would have accrued under petitioner's…
1Opinion of the Court
Raleigh Properties, Inc. v. Commissioner.
Raleigh Properties, Inc. v. Commissioner
Docket No. 86988.
United States Tax Court
T.C. Memo 1962-150; 1962 Tax Ct. Memo LEXIS 161; 21 T.C.M. (CCH) 812; T.C.M. (RIA) 62150;
June 22, 1962
Petitioner purchased a hotel in 1953 for a stated purchase price of $3,240,000. Sellers took back an 11-year note in the stated amount of $1,548,739.10. The contract recites that the note is to be without interest, but it includes a prepayment discount schedule. Earlier negotiations contemplated a purchase price of $2,800,000, with the sellers taking back a note bearing…
2Cases cited7 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Mills v. CommissionerUnited States Tax Court · 1948
- C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949
- Elliott Paint & Varnish Co. v. CommissionerUnited States Board of Tax Appeals · 1941
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