Williams v. Commissioner
United States Tax Court
P entered into an agreement to purchase a vacation condominium for a stated purchase price in excess of $ 1.5 million. P executed an installment note calling for two payments of the stated purchase price, the first installment due in just over 6 months and the second due in 30 years.
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P entered into an agreement to purchase a vacation condominium for a stated purchase price in excess of $ 1.5 million. P executed an installment note calling for two payments of the stated purchase price, the first installment due in just over 6 months and the second due in 30 years. P claims that the first installment is a payment to which sec. 483, I.R.C., applies and that unstated interest is allocated to such first installment pursuant to sec. 1.483-1(a)(1), Income Tax Regs.Held: P has failed to show that the benefits and burdens of ownership of the condominium were acquired more than 6…
1Opinion of the Court
LLOYD E. WILLIAMS, JR. AND MILDRED A. WILLIAMS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Williams v. Commissioner
Docket No. 36698-87
United States Tax Court
T.C. Memo 1992-269; 1992 Tax Ct. Memo LEXIS 292; 63 T.C.M. (CCH) 2959;
May 11, 1992, Filed
Decision will be entered under Rule 155.
P entered into an agreement to purchase a vacation condominium for a stated purchase price in excess of $ 1.5 million. P executed an installment note calling for two payments of the stated purchase price, the first installment due in just over 6 months and the second due in 30 years. P claims…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. BrownSupreme Court of the United States · 1965
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
19 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Lloyd E. Williams, Jr. And Mildred A. Williams v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1993
- Benedict v. United StatesDistrict Court, D. Utah · 1995