CASHION, INC. v. COMMISSIONER
United States Tax Court
In 1968, A and B transferred certain developed properties to X corporation in exchange for certain mountain properties. However, neither party realized that the deed from X to A and B mistakenly omitted 82.2 acres. In 1970, A and B conveyed an undivided two-thirds interest in the entire mountain properties to C and D. In 1973, A, B, C, and D sold such mountain properties to M, who subsequently discovered that X still held record title to the omitted 82.2 acres.
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In 1968, A and B transferred certain developed properties to X corporation in exchange for certain mountain properties. However, neither party realized that the deed from X to A and B mistakenly omitted 82.2 acres. In 1970, A and B conveyed an undivided two-thirds interest in the entire mountain properties to C and D. In 1973, A, B, C, and D sold such mountain properties to M, who subsequently discovered that X still held record title to the omitted 82.2 acres. At M's request, X deeded the 82.2 acres to A and B. Held, under the facts of this case, A and B, and not X, owned the 82.2 acres when…
1Opinion of the Court
CASHION, INC., FORMERLY CASHION OIL COMPANY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; PAUL L. CASHION and MARY E. CASHION, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
CASHION, INC. v. COMMISSIONER
Docket Nos. 8536-76, 8537-76.
United States Tax Court
T.C. Memo 1978-466; 1978 Tax Ct. Memo LEXIS 49; 37 T.C.M. (CCH) 1847-96;
November 22, 1978, Filed
In 1968, A and B transferred certain developed properties to X corporation in exchange for certain mountain properties. However, neither party realized that the deed from X to A and B mistakenly omitted 82.2 acres.…
2Cases cited7 opinions
- Baird v. CommissionerUnited States Tax Court · 1977
- Commissioner of Internal Revenue v. SegallCourt of Appeals for the Sixth Circuit · 1940
- Deyoe v. CommissionerUnited States Tax Court · 1976
- Margaret v. Dettmers, Estate of Herrick L. Johnston, Deceased, and Margaret v. Dettmers, Individually v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Estate of Johnston v. CommissionerUnited States Tax Court · 1968
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