Legal Opinion

Koch v. Commissioner

United States Tax Court

Decided October 23, 1978No. Docket No. 9648-76Published

In 1973 and 1974, petitioners exchanged unencumbered parcels of real estate which they owned in fee simple for parcels of real estate which were subject to 99-year condominium leases. Held, the properties so exchanged are properties of a like kind within the meaning of sec. 1031(a), I.R.C. 1954, and no gain is recognized on the exchanges.

1Opinion of the Court

Carl E. Koch and Paula Koch; Frederick W. Koch and Robin E. Koch, a.k.a., Robin E. Pruitt; William A. Bomberger and Carolyn L. Bomberger; and John J. Koch, Petitioners v. Commissioner of Internal Revenue, Respondent

Koch v. Commissioner

Docket No. 9648-76

United States Tax Court

71 T.C. 54; 1978 U.S. Tax Ct. LEXIS 41;

October 23, 1978, Filed

Decision will be entered under Rule 155.

In 1973 and 1974, petitioners exchanged unencumbered parcels of real estate which they owned in fee simple for parcels of real estate which were subject to 99-year condominium leases. Held, the properties so exchanged are…

2Cases cited25 opinions

  1. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  2. Morris Lipsitz, and Morris Lipsitz and Helen Lipsitz v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
  3. Biggs v. CommissionerUnited States Tax Court · 1978
  4. Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
  5. Koch v. CommissionerUnited States Tax Court · 1978

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