Legal Opinion

Park Realty Co. v. Commissioner

United States Tax Court

Decided August 13, 1981No. Docket No. 12676-79Published

Petitioner commenced development of a shopping center on land which it owned, incurred development costs exclusive of land costs in the amount of $ 351,575.11, and negotiated tentative agreements whereby certain retailers would occupy the center as anchor stores. Unable to obtain adequate financing, petitioner formed a partnership with an affiliate of a large developer, and petitioner transferred its interest in the property to the partnership.

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Petitioner commenced development of a shopping center on land which it owned, incurred development costs exclusive of land costs in the amount of $ 351,575.11, and negotiated tentative agreements whereby certain retailers would occupy the center as anchor stores. Unable to obtain adequate financing, petitioner formed a partnership with an affiliate of a large developer, and petitioner transferred its interest in the property to the partnership. Pursuant to the partnership agreement, upon consummation of binding agreements with the anchor stores, petitioner received payments in the amount of $…

1Opinion of the Court

Park Realty Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Park Realty Co. v. Commissioner

Docket No. 12676-79

United States Tax Court

77 T.C. 412; 1981 U.S. Tax Ct. LEXIS 75;

August 13, 1981, Filed

Decision will be entered under Rule 155.

Petitioner commenced development of a shopping center on land which it owned, incurred development costs exclusive of land costs in the amount of $ 351,575.11, and negotiated tentative agreements whereby certain retailers would occupy the center as anchor stores. Unable to obtain adequate financing, petitioner formed a partnership with an…

2Cases cited4 opinions

  1. Otey v. CommissionerUnited States Tax Court · 1978
  2. John H. Otey, Jr. And Bettye G. Otey v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
  3. Barenholtz v. CommissionerUnited States Tax Court · 1981
  4. Park Realty Co. v. CommissionerUnited States Tax Court · 1981

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