Stahl v. Commissioner
United States Tax Court
Petitioners, in consideration for property, promised to provide a residence to A and B for the rest of A and B's lives. Held, the transaction was a lease with an advance rental payment in the form of property. Held further, petitioners' basis in such property for the purpose of determining gain on subsequent disposition is the fair market value of the property as of the date of acquisition. Held further, fair market value determined.
1Opinion of the Court
DAVID E. AND BARBARA A. STAHL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Stahl v. Commissioner
Docket No. 16034-85.
United States Tax Court
T.C. Memo 1987-323; 1987 Tax Ct. Memo LEXIS 323; 53 T.C.M. (CCH) 1273; T.C.M. (RIA) 87323;
June 29, 1987.
Petitioners, in consideration for property, promised to provide a residence to A and B for the rest of A and B's lives. Held, the transaction was a lease with an advance rental payment in the form of property. Held further, petitioners' basis in such property for the purpose of determining gain on subsequent disposition is the fair market…
2Cases cited8 opinions
- Koch v. CommissionerUnited States Tax Court · 1978
- United States v. Dresser Industries, Inc.Court of Appeals for the Fifth Circuit · 1963
- Regals Realty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Griffin v. CommissionerUnited States Tax Court · 1967
- Greenwood Packing Plant v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
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3Cited by3 opinions
- Premier Capital Funding, Inc. v. Earle (In Re Earle)United States Bankruptcy Court, S.D. Alabama · 2002
- Crooks v. CommissionerUnited States Tax Court · 1989
- Crooks v. CommissionerUnited States Tax Court · 1989