Foster v. Comm'r
United States Tax Court
SUBSTANTIVE ISSUES Issues 1 and 3: REALLOCATIONS OF INCOME UNDER SEC. 482, I.R.C. 1954. T, J, D, and B (a father and three sons) were equal partners in FP, a general partnership. In 1958, FP began to investigate the development potential of Brewer's Island, a 2,600-acre undeveloped tract of land located about 12 miles south of San Francisco.
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SUBSTANTIVE ISSUES Issues 1 and 3: REALLOCATIONS OF INCOME UNDER SEC. 482, I.R.C. 1954. T, J, D, and B (a father and three sons) were equal partners in FP, a general partnership. In 1958, FP began to investigate the development potential of Brewer's Island, a 2,600-acre undeveloped tract of land located about 12 miles south of San Francisco. FP determined that the tract could be transformed into a city of 35,000. In December 1959, it acquired an option for the purchase of the land; in May 1960, it secured enabling legislation from the California legislature for a municipal improvement…
1Opinion of the Court
Dawson, Judge-.
Respondent determined the following deficiencies in petitioners’ Federal income taxes and additions to tax under sections 6651(a)(1) and 6653(a):1
Addition
Petitioner Year Deficiency to tax
Richard H. Foster 1963 $108,513.06
and Sara B. Foster 1964 177,066.45
1965 277,166.65
1966 5,630.26
1967 133,246.08
701,622.50
T. Jack Foster, Jr., 1963 110,067.16
and Patricia Foster 1964 184,431.45
1965 283,634.67
1966 5,764.04
1967 137,755.12
721,652.44
John R. Foster 1963 108,997.49
and Caroline Foster 1964 176,869.03 $8,843.45
1965 275,674.76
1966 4,268.35
1967 129,602.81
695,412.44 28,843.45
Estate of T.…
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