Perlmutter v. Commissioner
United States Tax Court
Petitioners were partners in Perl-Mack Construction Co., which subdivided land and built and sold homes located in two subdivisions, Perl-Mack Manor and Northglenn, in Adams County, Colo. The regulations of the Adams County Planning and Zoning Board required subdividers to allocate and convey land to the county for public purposes.
Read the full summary
Petitioners were partners in Perl-Mack Construction Co., which subdivided land and built and sold homes located in two subdivisions, Perl-Mack Manor and Northglenn, in Adams County, Colo. The regulations of the Adams County Planning and Zoning Board required subdividers to allocate and convey land to the county for public purposes. Perl-Mack transferred three parcels of land to school districts and one parcel to a recreation district in ostensible compliance with these regulations. Subsequently it claimed deductions for the fair market value of these parcels as charitable contributions on the…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ income tax returns for the years and in the amounts as follows:
[[Image here]]
The above six docket numbers have been consolidated for trial and decision. In docket Nos. 1785-68, 1786-63, and 1787-63, the respondent has conceded certain issues which substantially reduce the deficiencies set forth in the statutory notice. Also in those docket numbers the petitions were amended to claim additional deductions for charitable contributions which would result in the Court finding overpay-ments of taxes by petitioners and awarding…
2Cases cited19 opinions
- Village of Euclid v. Ambler Realty Co.Supreme Court of the United States · 1926
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Bogardus v. CommissionerSupreme Court of the United States · 1937
14 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Foster v. Comm'rUnited States Tax Court · 1983
- United States v. Transamerica Corporation, Transamerica Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1968
- Edgar v. CommissionerUnited States Tax Court · 1971
- Seed v. CommissionerUnited States Tax Court · 1971
50 more not listed; retrieve them via the Exa API.