Allison v. Commissioner
United States Tax Court
Acceptance and Investment entered into an agreement to acquire and develop property. A portion of the property was distributed to Acceptance who subsequently through a subsidiary, Mortgage, distributed to each Allison and Krikac, its officers, one of the subdivided lots.
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Acceptance and Investment entered into an agreement to acquire and develop property. A portion of the property was distributed to Acceptance who subsequently through a subsidiary, Mortgage, distributed to each Allison and Krikac, its officers, one of the subdivided lots. Held: There was no provision for sharing profits and losses, Acceptance was entitled (between the parties) to certain property in all events and hence there could be no joint venture; the receipt of the property by Acceptance represents ordinary income for services rendered. Held further: Fair market value of the property…
1Opinion of the Court
IAN T. ALLISON, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Allison v. Commissioner
Docket Nos. 3320-73, 3361-73 3362-73, 3386-73
United States Tax Court
T.C. Memo 1976-248; 1976 Tax Ct. Memo LEXIS 153; 35 T.C.M. (CCH) 1069; T.C.M. (RIA) 760248;
August 11, 1976, Filed
Acceptance and Investment entered into an agreement to acquire and develop property. A portion of the property was distributed to Acceptance who subsequently through a subsidiary, Mortgage, distributed to each Allison and Krikac, its officers, one of the subdivided lots. Held: There was no provision for…
2Cases cited12 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Shomaker v. CommissionerUnited States Tax Court · 1962
- Podell v. CommissionerUnited States Tax Court · 1970
7 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Estate of English v. CommissionerUnited States Tax Court · 1985