Mitchell v. Commissioner
United States Tax Court
In June 1959 petitioner George W. Mitchell purchased at public auction the property in Baltimore, Md., known as Old Sinai Hospital for the price of $ 708,000. Thereafter, petitioner entered into a joint venture with two individuals (both now deceased) whereby title to the purchased property was taken in the names of the three joint venturers, with petitioner having a 40-percent interest and the other two a 40-percent and 20-percent interest, respectively.
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In June 1959 petitioner George W. Mitchell purchased at public auction the property in Baltimore, Md., known as Old Sinai Hospital for the price of $ 708,000. Thereafter, petitioner entered into a joint venture with two individuals (both now deceased) whereby title to the purchased property was taken in the names of the three joint venturers, with petitioner having a 40-percent interest and the other two a 40-percent and 20-percent interest, respectively. Settlement on the property was held on Jan. 29, 1960. The property was so held until the year 1961 when it was sold in two portions for a…
1Opinion of the Court
Auundell, Judge:
Respondent determined deficiencies in income tax for the calendar years 1960 and 1961 in the amounts of $3,447.73 and $21,823.53, respectively. Since petitioners are not contesting an adjustment in each year for entertainment and travel expense of $1,200, deducted by petitioners on their returns, the entire deficiencies are not in controversy. The issues presented for our decision are: (1) Whether a joint venture, in which petitioner George W. Mitchell 'had a 40-percent interest, was entitled to report the gain on the sale in 1961 of the property known as Old Sinai Hospital as…
2Cases cited16 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Burnet v. ClarkSupreme Court of the United States · 1932
- Thrift v. CommissionerUnited States Tax Court · 1950
- Farley v. CommissionerUnited States Tax Court · 1946
- Robinson v. CommissionerUnited States Tax Court · 1943
11 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Green v. Comm'rUnited States Tax Court · 1984
- Newcombe v. CommissionerUnited States Tax Court · 1970
- Deely v. CommissionerUnited States Tax Court · 1980
- John R. Carkhuff Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Lyle S. Simonson and Donna Simonson v. United StatesCourt of Appeals for the Eighth Circuit · 1985
25 more not listed; retrieve them via the Exa API.