James S. & Carol S. Callahan v. Commissioner

T.C. Memo. 2013-131

UNITED STATES TAX COURT JAMES S. CALLAHAN AND CAROL S. CALLAHAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13859-10. Filed May 22, 2013. P-W was facing foreclosure on two pieces of real property. She discussed the matter with a promoter of certain sale-leaseback transactions who informed P-W that the transactions could save her properties from foreclosure. P-W entered into the transactions, under which: (1) P-W sold each property to the promoter’s designee and leased the property back for a year with an option to purchase the property upon…