Tecumseh Corrugated Box Co. v. Commissioner
United States Tax Court
In February 1984, P sold four unimproved parcels of real estate to the Federal Government. In May 1984, P sold its remaining improved parcel of real estate to T, a related party, under an installment contract.
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In February 1984, P sold four unimproved parcels of real estate to the Federal Government. In May 1984, P sold its remaining improved parcel of real estate to T, a related party, under an installment contract. In December 1984, T sold the improved parcel of real estate to the Government for $ 4.5 million payable $ 2 million in January 1985 and $ 2.5 million in May 1985. Held: 1. The December 1984 sale to the Government represents a second disposition by a related party, subject to sec. 453(e)(1). 2. The exception provided by sec. 453(e)(6) is not applicable because the December 1984 sale was…
1Opinion of the Court
COHEN, Judge:
Respondent determined deficiencies of $11,516.14 and $1,167,201.84 in petitioner’s Federal income taxes for the fiscal years ended October 31, 1984 and 1985, respectively. The sole issue for decision is whether section 453(e) applies to certain sales of real property by petitioner.
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set forth in the…
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Maixner v. CommissionerUnited States Tax Court · 1959
- S. & B. Realty Co. v. CommissionerUnited States Tax Court · 1970
- Rainier Cos. v. CommissionerUnited States Tax Court · 1973
- Eugene W. And Marie P. Fireoved, in Nos. 71-1565 v. United States of America, in Nos. 71-1566, 71-1567Court of Appeals for the Third Circuit · 1972
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Shelton v. CommissionerUnited States Tax Court · 1995
- Tecumseh Corrugated Box Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Affordable Communities of MO v. Federal Nat'l Mortgage Assoc.Court of Appeals for the Eighth Circuit · 2016
- Guenther v. CommissionerUnited States Tax Court · 1995
- Shelton v. CommissionerUnited States Tax Court · 1995
1 more not listed; retrieve them via the Exa API.