Legal Opinion

Bennett Land Co. (A Washington Corp.) v. Commissioner

United States Tax Court

Decided September 13, 1978No. Docket No. 3924-75Published

Prior to the sale of farmland to the taxpayer, the seller had summer fallowed the land, incurring expenses of $ 1,800. The sales agreement allocated $ 5,500 of the purchase price to the increase in the fair market value of the land due to its being summer fallowed. Held, neither the expenses attributable to the summer fallow nor the increase in the land's fair market value due to the summer fallow are deductible by the purchaser.

1Opinion of the Court

Bennett Land Company (A Washington Corporation), Petitioner v. Commissioner of Internal Revenue, Respondent

Bennett Land Co. (A Washington Corp.) v. Commissioner

Docket No. 3924-75

United States Tax Court

70 T.C. 904; 1978 U.S. Tax Ct. LEXIS 58;

September 13, 1978, Filed

Decision will be entered for the respondent.

Prior to the sale of farmland to the taxpayer, the seller had summer fallowed the land, incurring expenses of $ 1,800. The sales agreement allocated $ 5,500 of the purchase price to the increase in the fair market value of the land due to its being summer fallowed. Held, neither the…

2Cases cited10 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Edwards v. Cuba RailroadSupreme Court of the United States · 1925
  5. Commissioner of Internal Revenue v. D. B. AndersCourt of Appeals for the Tenth Circuit · 1969

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