Bailey v. Commissioner
United States Tax Court
P bought property in an area subject to an urban renewal project. As a participant in a program that was part of the project, P received a facade grant. According to the terms of the grant, the city's urban renewal agency (URA) agreed to restore the facade on P's building and P promised to rehabilitate the interior of the building and to maintain the facade.
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P bought property in an area subject to an urban renewal project. As a participant in a program that was part of the project, P received a facade grant. According to the terms of the grant, the city's urban renewal agency (URA) agreed to restore the facade on P's building and P promised to rehabilitate the interior of the building and to maintain the facade. The URA contracted for the facade rehabilitation and was the party that chose the contractor, negotiated the terms of the contract, and paid the contractor directly for the work. P was not permitted to alter the facade in any way without…
1Opinion of the Court
NlMS, Judge:
By notice of deficiency dated March 28, 1985, respondent determined deficiencies in petitioner’s income tax for the following taxable years:
Year Deficiency
1977 . $986.40
1978 . 32,424.61
1980 . 970.00
1981 . 624.00
By notice of deficiency dated March 14, 1986, respondent determined a deficiency in petitioner’s income tax for the 1979 taxable year in the amount of $28,615.66. Respondent’s amended answer alleged an additional deficiency in petitioner’s income tax in the amount of $754.60 for the taxable year 1977.
The issues for decision are: (1) Whether the payments made by the Urban…
2Cases cited9 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Helvering v. BruunSupreme Court of the United States · 1940
- Graff v. CommissionerUnited States Tax Court · 1980
- Alvin v. Graff v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1982
4 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Union Pacific Corp. v. CommissionerUnited States Tax Court · 1988
- Maines v. Comm'rUnited States Tax Court · 2015
- Bannon v. CommissionerUnited States Tax Court · 1992
- (2010), Maryland Attorney General Reports2010
- Bailey v. CommissionerUnited States Tax Court · 1987
8 more not listed; retrieve them via the Exa API.