Legal Opinion

Grow v. Commissioner

United States Tax Court

Decided January 31, 1983No. Docket Nos. 20871-80, 23209-80PublishedCited by 10 opinions

In 1975, petitioners, through a partnership, purchased a mobile home park which included a private water and sewer distribution system. At the time of purchase, the original developer and seller of this mobile home park, M & H Investment, had rented 82 of 398 mobile home sites. After the partnership acquired this property, it leased this mobile home park back to M & H Investment.

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In 1975, petitioners, through a partnership, purchased a mobile home park which included a private water and sewer distribution system. At the time of purchase, the original developer and seller of this mobile home park, M & H Investment, had rented 82 of 398 mobile home sites. After the partnership acquired this property, it leased this mobile home park back to M & H Investment. In 1976, the lease terminated, and the partnership assumed responsibility for the management of the mobile home park. The partnership maintained two separate businesses; that is, it was in the business of providing…

1Opinion of the Court

Korner, Judge:

Respondent determined deficiencies in petitioners’ Federal income taxes as follows:

Petitioners Year Deficiency

David S. and Judith W. Grow . 1973 $99.00

1974 1,108.00

Robert G. and Rochelle R. Wilson . 1975 2,237.00

Raymond O. and Cicily M. Christensen . 1972 $483.00

1975 3,682.00

Jerald J. and Anne B. Bergera . 1975 2,445.72

Maurice K. and Marilyn M. Roskelley . 1975 3,060.62

Robert H. and Barbara K. Nelson . 1975 6,038.30

George A. and Armanell Francom . 1975 7,299.00

By order of this Court, these cases were consolidated for purposes of trial, briefing, and opinion.

The ultimate issue…

2Cases cited17 opinions

  1. Dreicer v. CommissionerUnited States Tax Court · 1982
  2. Golanty v. CommissionerUnited States Tax Court · 1979
  3. Brannen v. CommissionerUnited States Tax Court · 1982
  4. Achiro v. CommissionerUnited States Tax Court · 1981
  5. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964

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

3Cited by10 opinions

  1. Waddell v. CommissionerUnited States Tax Court · 1986
  2. Levy v. CommissionerUnited States Tax Court · 1988
  3. Helfand v. CommissionerUnited States Tax Court · 1984
  4. Hub City Foods, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
  5. Grow v. CommissionerUnited States Tax Court · 1983

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

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