Tecumseh Corrugated Box Co. v. Commissioner
United States Tax Court
In February 1984, P sold four unimproved parcels of real estate to the Federal Government. In May 1984, P sold its remaining improved parcel of real estate to T, a related party, under an installment contract.
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In February 1984, P sold four unimproved parcels of real estate to the Federal Government. In May 1984, P sold its remaining improved parcel of real estate to T, a related party, under an installment contract. In December 1984, T sold the improved parcel of real estate to the Government for $ 4.5 million payable $ 2 million in January 1985 and $ 2.5 million in May 1985. Held: 1. The December 1984 sale to the Government represents a second disposition by a related party, subject to sec. 453(e)(1). 2. The exception provided by sec. 453(e)(6) is not applicable because the December 1984 sale was…
1Opinion of the Court
Tecumseh Corrugated Box Co., Petitioner v. Commissioner of Internal Revenue, Respondent
Tecumseh Corrugated Box Co. v. Commissioner
Docket No. 26458-88
United States Tax Court
94 T.C. 360; 1990 U.S. Tax Ct. LEXIS 22; 94 T.C. No. 22;
March 12, 1990March 12, 1990, Filed
Decision will be entered under Rule 155.
In February 1984, P sold four unimproved parcels of real estate to the Federal Government. In May 1984, P sold its remaining improved parcel of real estate to T, a related party, under an installment contract. In December 1984, T sold the improved parcel of real estate to the Government for $…
2Cases cited11 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Maixner v. CommissionerUnited States Tax Court · 1959
- S. & B. Realty Co. v. CommissionerUnited States Tax Court · 1970
- Rainier Cos. v. CommissionerUnited States Tax Court · 1973
- Eugene W. And Marie P. Fireoved, in Nos. 71-1565 v. United States of America, in Nos. 71-1566, 71-1567Court of Appeals for the Third Circuit · 1972
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