Legal Opinion

Nevin v. Commissioner

United States Tax Court

Decided March 15, 1965No. Docket No. 92562Unpublished

Petitioner, a real estate dealer, together with a group of coventurers acquired several adjacent tracts of land, together with water stock and rights. They immediately resold the land. Subsequently, the contract for resale was partially rescinded and petitioner and his coventurers reacquired some of the tracts. Within the following 18 months 193 of the 208 acres reacquired were sold off or optioned in seven separate transactions.

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Petitioner, a real estate dealer, together with a group of coventurers acquired several adjacent tracts of land, together with water stock and rights. They immediately resold the land. Subsequently, the contract for resale was partially rescinded and petitioner and his coventurers reacquired some of the tracts. Within the following 18 months 193 of the 208 acres reacquired were sold off or optioned in seven separate transactions. Two of these sales were to controlled conduits which immediately resold individual lots on a lot-by-lot basis. Petitioner engaged in no advertising or other active…

1Opinion of the Court

Thomas W. and Mary E. Nevin v. Commissioner.

Nevin v. Commissioner

Docket No. 92562.

United States Tax Court

T.C. Memo 1965-53; 1965 Tax Ct. Memo LEXIS 277; 24 T.C.M. (CCH) 294; T.C.M. (RIA) 65053;

March 15, 1965

Petitioner, a real estate dealer, together with a group of coventurers acquired several adjacent tracts of land, together with water stock and rights. They immediately resold the land. Subsequently, the contract for resale was partially rescinded and petitioner and his coventurers reacquired some of the tracts. Within the following 18 months 193 of the 208 acres reacquired were sold off or…

2Cases cited27 opinions

  1. MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
  2. Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Mauldin v. CommissionerUnited States Tax Court · 1951
  4. Snell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1938
  5. Farley v. CommissionerUnited States Tax Court · 1946

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