Palo Alto Town & Country Village, Inc. v. Commissioner
United States Tax Court
Held: 1. The separate cost of the two tracts of land purchased by Ronald and Ann Williams in 1959 determines the basis of the parcel he sold from one of these tracts during the taxable year 1963. 2. Ronald Williams and Palo Alto Town & Country Village, Inc. have not established by a preponderance of the evidence that they are entitled to any amount with respect to the cost of operating a chartered airplane on a 24-hour standby basis in addition to the $125 per hour for…
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Held: 1. The separate cost of the two tracts of land purchased by Ronald and Ann Williams in 1959 determines the basis of the parcel he sold from one of these tracts during the taxable year 1963. 2. Ronald Williams and Palo Alto Town & Country Village, Inc. have not established by a preponderance of the evidence that they are entitled to any amount with respect to the cost of operating a chartered airplane on a 24-hour standby basis in addition to the $125 per hour for actual flying time allowed by respondent during the taxable years involved. 2 3. Respondent properly allocated the income…
1Opinion of the Court
PALO ALTO TOWN & COUNTRY VILLAGE, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Palo Alto Town & Country Village, Inc. v. Commissioner
Docket Nos. 5947-70, 5948-70, 5949-70.
United States Tax Court
T.C. Memo 1973-223; 1973 Tax Ct. Memo LEXIS 63; 32 T.C.M. (CCH) 1048; T.C.M. (RIA) 73223;
October 10, 1973, Filed
Held:
1. The separate cost of the two tracts of land purchased by Ronald and Ann Williams in 1959 determines the basis of the parcel he sold from one of these tracts during the taxable year 1963.
2. Ronald Williams and Palo Alto Town & Country Village, Inc. have…
2Cases cited19 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- United States v. Gilbert Associates, Inc.Supreme Court of the United States · 1953
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Ashby v. CommissionerUnited States Tax Court · 1968
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