Legal Opinion

Goodman v. Commissioner

United States Tax Court

Decided July 16, 1980No. Docket No. 3229-78PublishedCited by 27 opinions

Held: 1. The sale of an apartment building by two individuals to trusts of which they were trustees were bona fide sales recognizable of tax purposes where the declarations of trusts authorized such sales and the sales were advantageous to the trusts even though the following day the trusts sold the apartments to a third party; 2. Where the mortgage note provided for payments by the purchaser of property to a bank so long as purchaser had the written commitment of the bank…

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Held: 1. The sale of an apartment building by two individuals to trusts of which they were trustees were bona fide sales recognizable of tax purposes where the declarations of trusts authorized such sales and the sales were advantageous to the trusts even though the following day the trusts sold the apartments to a third party; 2. Where the mortgage note provided for payments by the purchaser of property to a bank so long as purchaser had the written commitment of the bank to make payments from the funds received from the purchaser on a preexisting mortgage, purchaser took property subject to…

1Opinion of the Court

Scott, Judge:

Respondent determined the following deficiencies and additions to tax under section 6653(a), I.R.C. 1954,1 in petitioners’ Federal income taxes for the calendar year 1973:

Deficiencies Additions to tax Name in income tax under sec. 6653(a)

William J. and Gloria Goodman.$55,346.51 $2,767.33

Norman A. and Marilyn Rossman.51,701.07 2,585.05

Barry S. Goodman. 865.00 0

Lauren B. Goodman. 865.00 0

Michael A. Goodman. 705.05 0

Paula M. Rossman. 692.00 0

Following concessions by each of the parties, the issues remaining for decision are: (1) Whether the sale of apartments by petitioners William…

2Cases cited36 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Griffiths v. CommissionerSupreme Court of the United States · 1939
  3. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  4. Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
  5. Rushing v. CommissionerUnited States Tax Court · 1969

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

3Cited by27 opinions

  1. Hunt v. CommissionerUnited States Tax Court · 1983
  2. Bowen v. CommissionerUnited States Tax Court · 1982
  3. Professional Equities v. CommissionerUnited States Tax Court · 1987
  4. May v. CommissionerUnited States Tax Court · 1981
  5. Vaughn v. CommissionerUnited States Tax Court · 1983

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

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