Legal Opinion

Filler v. Commissioner

United States Tax Court

Decided September 17, 1987No. Docket Nos. 37937-85; 37943-85; 319-86; 320-86; 6417-86; 6420-86UnpublishedCited by 2 opinions

Fs and S owned land as tenants in common. Fs were the sole shareholders of a corporation and sole trustees and beneficiaries of its pension trust. S was the sole shareholder of another corporation and sole trustee and beneficiary of its pension trust. Each co-owner of the land simultaneously granted to the other co-owner's pension trust an option to buy an undivided one-half interest in the land on identical terms.

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Fs and S owned land as tenants in common. Fs were the sole shareholders of a corporation and sole trustees and beneficiaries of its pension trust. S was the sole shareholder of another corporation and sole trustee and beneficiary of its pension trust. Each co-owner of the land simultaneously granted to the other co-owner's pension trust an option to buy an undivided one-half interest in the land on identical terms. Thereafter, the options were exercised and the land was immediately sold to a third party. Held: On consideration of all the facts, the substance of the transaction as a whole was…

1Opinion of the Court

GEORGE FILLER AND EVELYN FILLER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Filler v. Commissioner

Docket Nos. 37937-85; 37943-85; 319-86; 320-86; 6417-86; 6420-86.

United States Tax Court

T.C. Memo 1987-468; 1987 Tax Ct. Memo LEXIS 464; 54 T.C.M. (CCH) 557; T.C.M. (RIA) 87468;

September 17, 1987.

Fs and S owned land as tenants in common. Fs were the sole shareholders of a corporation and sole trustees and beneficiaries of its pension trust. S was the sole shareholder of another corporation and sole trustee and beneficiary of its pension trust. Each co-owner of the land…

2Cases cited21 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Corliss v. BowersSupreme Court of the United States · 1930
  5. National Labor Relations Board v. Amax Coal Co.Supreme Court of the United States · 1981

16 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Lefrak v. CommissionerUnited States Tax Court · 1993
  2. Melnik v. Comm'rUnited States Tax Court · 2006

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