Legal Opinion

Bolker v. Commissioner

United States Tax Court

Decided October 20, 1983No. Docket Nos. 7100-77, 8379-78Published

Petitioner and his wife were equal shareholders of a corporation owning undeveloped land. In May 1969, after the corporation granted an option to a bank to purchase the land, the bank decided to exercise the option, but failed to execute the sale. From April 1970 until September 1970, petitioner and the bank exchanged various offers and counteroffers regarding the sale and exchange of the corporate property.

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Petitioner and his wife were equal shareholders of a corporation owning undeveloped land. In May 1969, after the corporation granted an option to a bank to purchase the land, the bank decided to exercise the option, but failed to execute the sale. From April 1970 until September 1970, petitioner and the bank exchanged various offers and counteroffers regarding the sale and exchange of the corporate property. After petitioner's divorce in September 1970, he became sole shareholder in the corporation and, upon the advice of his attorneys, he decided to remove the property from the corporation…

1Opinion of the Court

Joseph R. Bolker, Petitioner v. Commissioner of Internal Revenue, Respondent

Bolker v. Commissioner

Docket Nos. 7100-77, 8379-781

United States Tax Court

81 T.C. 782; 1983 U.S. Tax Ct. LEXIS 18; 81 T.C. No. 48;

October 20, 1983, Filed

Decisions will be entered under Rule 155.

Petitioner and his wife were equal shareholders of a corporation owning undeveloped land. In May 1969, after the corporation granted an option to a bank to purchase the land, the bank decided to exercise the option, but failed to execute the sale. From April 1970 until September 1970, petitioner and the bank exchanged various…

2Cases cited23 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  3. Central Tablet Manufacturing Co. v. United StatesSupreme Court of the United States · 1974
  4. Court Holding Co. v. CommissionerUnited States Tax Court · 1943
  5. Portland Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1940

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