Houlette v. Commissioner
United States Tax Court
Petitioner, Richard T. Houlette, a career Coast Guard officer, purchased a home in Portland, Oreg., in 1954. In 1955, upon receiving notice that he would be ordered to a new station in Alaska, he made unsuccessful efforts to sell the house. Shortly before his departure he rented the house for 2 years in order that he might avoid incurring a loss on the sale. At his new duty station, petitioner extended the 2-year lease on the house for another year.
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Petitioner, Richard T. Houlette, a career Coast Guard officer, purchased a home in Portland, Oreg., in 1954. In 1955, upon receiving notice that he would be ordered to a new station in Alaska, he made unsuccessful efforts to sell the house. Shortly before his departure he rented the house for 2 years in order that he might avoid incurring a loss on the sale. At his new duty station, petitioner extended the 2-year lease on the house for another year. The Portland property was being managed for petitioner in his absence by a real estate firm in that city. Petitioner continued to rent the…
1Opinion of the Court
Hoyt, Judge:
Respondent determined deficiencies in petitioners’ income tax for tbe year 1961 in tbe amount of $340.25. Tbe parties have reached agreement as to tbe correct disposition of certain casualty loss and travel expense issues which were raised by the petition. The single issue remaining for decision is whether the purchase by petitioners of a house in Manitowoc, Wis., followed by the sale of a house owned by them in Portland, Oreg., qualifies for treatment under section 1034,I.R.C. 1954,1 so that the gain realized on the sale of the Portland house will not be recognized in 1961.
EINDING…
2Cases cited5 opinions
- Stolk v. CommissionerUnited States Tax Court · 1963
- Bayley v. CommissionerUnited States Tax Court · 1960
- Shaeffer v. GilbertCourt of Appeals of Maryland · 1890
- Trisko v. CommissionerUnited States Tax Court · 1957
- Dwyer v. MatsonCourt of Appeals for the Tenth Circuit · 1947
3Cited by22 opinions
- Thomas v. CommissionerUnited States Tax Court · 1989
- Aagaard v. CommissionerUnited States Tax Court · 1971
- Clapham v. CommissionerUnited States Tax Court · 1975
- Bolaris v. CommissionerUnited States Tax Court · 1983
- Lewis Testamentary Trust B v. CommissionerUnited States Tax Court · 1984
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