Thompson v. Commissioner
United States Tax Court
1. Del Cerro Associates (DCA), a limited partnership, contracted to purchase certain land from Sunset International Petroleum Corp. (Sunset) for $ 1,456,000 in promissory notes. At the closing of the purchase DCA paid Sunset $ 350,000 in cash, which was designated as prepaid interest for 4 years on the purchase-money notes.
Read the full summary
1. Del Cerro Associates (DCA), a limited partnership, contracted to purchase certain land from Sunset International Petroleum Corp. (Sunset) for $ 1,456,000 in promissory notes. At the closing of the purchase DCA paid Sunset $ 350,000 in cash, which was designated as prepaid interest for 4 years on the purchase-money notes. Shortly thereafter, DCA granted Lion, a real estate broker wholly owned by Sunset, an exclusive and noncancellable right to improve and resell the property at a price of not less than $ 2,250,000. Held, the cash paid by DCA at the time of purchase of the property…
1Opinion of the Court
Dawson, Chief Judge:*
Respondent determined deficiencies in the income tax of petitioners in these consolidated cases as follows:
Docket No. Petitioners 1965 Taxable year 1966 1967
1164-70 Audrey M. Thompson_$7,018.41 $4,725.00 ---
1330-70 Florence Ain and Gregory Ain_ 1,334.28 1,507.20 ---
1336-70 Dorothy E. Kahan and Robert Kahan_ 5,881.19 5,332.76 ---
3015-70 Nana Berman and William Berman_ 3,394.51 3,481.40 $6,802.21
The four consolidated cases, as well as the related cases referred to in footnote 1, are all concerned with a series of transactions during the years 1965 through 1967, involving…
2Cases cited18 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Massachusetts Mutual Life Insurance v. United StatesSupreme Court of the United States · 1933
- Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
13 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Falsetti v. CommissionerUnited States Tax Court · 1985
- Narver v. CommissionerUnited States Tax Court · 1980
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Karme v. CommissionerUnited States Tax Court · 1980
- Bail Bonds by Marvin Nelson, Inc., a Corporation v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
31 more not listed; retrieve them via the Exa API.