Bergstrom v. United States

OPINION

MOODY R. TIDWELL, III, Judge:

This case arises out of plaintiffs motion for partial summary judgment, filed Api’il 26, 1996, and defendant’s cross motion for partial summary judgment, filed May 21,1996. The parties dispute whether nonrecourse purchase money debt that does not reasonably approximate fair market value of the related property is disregarded in its entirety for income tax purposes, or is disregarded only to the extent that such debt exceeds the fair market value of the property. The court holds that nonrecourse purchase money debt that does not reasonably approximate the…