Koch v. Commissioner
United States Tax Court
Petitioners owned real estate in Florida, most of which they had acquired in 1948 and 1949. In 1969 petitioners sold some of this property to a Florida corporation (Sunlife) and granted to Sunlife the option to purchase their remaining property for a period of 5 years provided Sunlife paid petitioners on a quarter annual basis 0.75 percent for the first year and 1 1/2 percent for each succeeding year of the stated purchase price of the property.
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Petitioners owned real estate in Florida, most of which they had acquired in 1948 and 1949. In 1969 petitioners sold some of this property to a Florida corporation (Sunlife) and granted to Sunlife the option to purchase their remaining property for a period of 5 years provided Sunlife paid petitioners on a quarter annual basis 0.75 percent for the first year and 1 1/2 percent for each succeeding year of the stated purchase price of the property. The agreement permitted exercise of the option with respect to part of the property without requiring its exercise as to all property. Thereafter,…
1Opinion of the Court
Carl E. Koch and Paula Koch, Petitioners v. Commissioner of Internal Revenue, Respondent
Koch v. Commissioner
Docket No. 8953-74
United States Tax Court
67 T.C. 71; 1976 U.S. Tax Ct. LEXIS 37;
October 19, 1976, Filed
Decision will be entered under Rule 155.
Petitioners owned real estate in Florida, most of which they had acquired in 1948 and 1949. In 1969 petitioners sold some of this property to a Florida corporation (Sunlife) and granted to Sunlife the option to purchase their remaining property for a period of 5 years provided Sunlife paid petitioners on a quarter annual basis 0.75 percent for…
2Cases cited23 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Commissioner v. BrownSupreme Court of the United States · 1965
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Mills v. CommissionerUnited States Tax Court · 1948
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
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