Legal Opinion

Friedman v. Comm'r

United States Tax Court

Decided June 28, 1977No. Docket Nos. 3858-73, 3859-73, 3860-73, 3861-73, 3862-73, 3863-73, 3864-73, 3865-73, 3866-73, 3867-73, 3868-73, 3869-73, 3870-73, 3871-73, 3872-73, 3873-73, 3874-73, 3875-73, 3876-73, 3467-74, 5856-74UnpublishedCited by 2 opinions

1. Petitioners undertook the development of a condominium complex. When the buildings were nearing completion, the common elements were submitted to condominium ownership. In accordance with a prearranged plan, the condominium association, which was likewise under the control of petitioners, entered into a 99-year lease for the recreational facilities which comprised a part of the project.

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1. Petitioners undertook the development of a condominium complex. When the buildings were nearing completion, the common elements were submitted to condominium ownership. In accordance with a prearranged plan, the condominium association, which was likewise under the control of petitioners, entered into a 99-year lease for the recreational facilities which comprised a part of the project. When the individual units were sold, the buyer assumed a pro rata share of the obligations under this lease. Held, the present value of the rentals under the 99-year recreational lease, to the extent in…

1Opinion of the Court

WILLIAM FRIEDMAN, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Friedman v. Comm'r

Docket Nos. 3858-73, 3859-73, 3860-73, 3861-73, 3862-73, 3863-73, 3864-73, 3865-73, 3866-73, 3867-73, 3868-73, 3869-73, 3870-73, 3871-73, 3872-73, 3873-73, 3874-73, 3875-73, 3876-73, 3467-74, 5856-74.

United States Tax Court

T.C. Memo 1977-201; 1977 Tax Ct. Memo LEXIS 243; 36 T.C.M. (CCH) 841; T.C.M. (RIA) 770201;

June 28, 1977, Filed

1. Petitioners undertook the development of a condominium complex. When the buildings were nearing completion, the common elements were submitted to condominium…

2Cases cited18 opinions

  1. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  2. Palmer v. CommissionerSupreme Court of the United States · 1937
  3. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  4. Morris Lipsitz, and Morris Lipsitz and Helen Lipsitz v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
  5. Albert Gersten, Myron P. Beck and Ann H. Beck, Milton Gersten and Mary Gersten v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959

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3Cited by2 opinions

  1. August Urbanek and Estate of Irene Urbanek, Deceased, August Urbanek, Personal Representative v. The United StatesCourt of Appeals for the Federal Circuit · 1984
  2. August Urbanek and Estate of Irene Urbanek, Deceased, August Urbanek, Personal Representative v. The United StatesCourt of Appeals for the Federal Circuit · 1984

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