Legal Opinion

Perlmutter v. Commissioner

United States Tax Court

Decided December 27, 1965No. Docket Nos. 1785-63, 1786-63, 1787-63, 1972-64, 1973-64, 1974-64Published

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.

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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

Jordon and Essie Perlmutter, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Perlmutter v. Commissioner

Docket Nos. 1785-63, 1786-63, 1787-63, 1972-64, 1973-64, 1974-64

United States Tax Court

45 T.C. 311; 1965 U.S. Tax Ct. LEXIS 2;

December 27, 1965, Filed

Decisions will be entered under Rule 50 in docket Nos. 1785-63, 1786-63, and 1787-63.

Decisions will be entered for the respondent in docket Nos. 1972-64, 1973-64, and 1974-64.

Petitioners were partners in Perl-Mack Construction Co., which subdivided land and built and sold homes located in two subdivisions, Perl-Mack Manor…

Also in this document: Concurrence.

2Cases cited21 opinions

  1. Village of Euclid v. Ambler Realty Co.Supreme Court of the United States · 1926
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
  4. Commissioner v. LoBueSupreme Court of the United States · 1956
  5. Bogardus v. CommissionerSupreme Court of the United States · 1937

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