Gladden v. Comm'r
United States Tax Court
On cross-motions for partial summary judgment, HELD, partnership water rights constitute capital assets. HELD, FURTHER, no portion of partnership's tax basis in land the partnership acquired in 1976 is to be allocated to the water rights the partnership acquired in 1983 and relinquished in 1992.
1Opinion of the Court
OPINION
Swift, Judge:
This matter is before us on the parties’ motions and cross-motions for partial summary judgment.
In 1993, as investors in a partnership named Saddle Mountain Ranch, which owned land in Harquahala Valley, Arizona (the partnership), petitioners received a portion of $28.7 million paid by the Federal Government to certain Harquahala Valley landowners in connection with the landowners’ relinquishment of the right each year to receive Colorado River water to irrigate their land (water rights).
Initially, the parties cross-move for partial summary judgment on the issue as to…
2Cases cited25 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Nevada v. United StatesSupreme Court of the United States · 1983
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Arizona v. CaliforniaSupreme Court of the United States · 1963
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3Cited by13 opinions
- Davis v. Comm'rUnited States Tax Court · 2002
- Tempel v. Comm'rUnited States Tax Court · 2011
- Gladden v. Comm'rUnited States Tax Court · 2003
- Womack v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2007
- Wiechens v. United StatesDistrict Court, D. Arizona · 2002
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