Major Realty Corp. v. Commissioner
United States Tax Court
Petitioner transferred a deed to 175 acres of land pursuant to a contract of sale. Under a Supplemental Contract, the parties agreed that the purchaser could choose another 175 acre parcel if the first was not suitable. Petitioner received a purchase money mortgage for 99 percent of the purchase price. Petitioner had the right to rescind the sale subsequent to closing if certain conditions were not met.
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Petitioner transferred a deed to 175 acres of land pursuant to a contract of sale. Under a Supplemental Contract, the parties agreed that the purchaser could choose another 175 acre parcel if the first was not suitable. Petitioner received a purchase money mortgage for 99 percent of the purchase price. Petitioner had the right to rescind the sale subsequent to closing if certain conditions were not met. Interest on the note would not accrue until after the expiration of the right of rescission. The conditions were not met by the purchaser and petitioner rescinded the sale. Upon rescission,…
1Opinion of the Court
MAJOR REALTY CORPORATION & SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Major Realty Corp. v. Commissioner
Docket No. 4871-75.
United States Tax Court
T.C. Memo 1981-361; 1981 Tax Ct. Memo LEXIS 386; 42 T.C.M. (CCH) 373; T.C.M. (RIA) 81361;
July 13, 1981.
Petitioner transferred a deed to 175 acres of land pursuant to a contract of sale. Under a Supplemental Contract, the parties agreed that the purchaser could choose another 175 acre parcel if the first was not suitable. Petitioner received a purchase money mortgage for 99 percent of the purchase price. Petitioner had…
2Cases cited77 opinions
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- Helvering v. CliffordSupreme Court of the United States · 1940
- Higgins v. SmithSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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