Rymer v. Commissioner
United States Tax Court
Petitioner, while working as an apartment building manager, bought an apartment building as a personal investment. Later, he lost his job and attempted to sell the apartment building. A potential buyer indicated interest in the building if petitioner could offer an adjacent parcel of land for sale along with the apartment building. Petitioner then acquired the adjacent parcel of land and sold it together with the apartment building to the purchaser for a single sale price.
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Petitioner, while working as an apartment building manager, bought an apartment building as a personal investment. Later, he lost his job and attempted to sell the apartment building. A potential buyer indicated interest in the building if petitioner could offer an adjacent parcel of land for sale along with the apartment building. Petitioner then acquired the adjacent parcel of land and sold it together with the apartment building to the purchaser for a single sale price. Held: (1) Petitioner did not hold the apartment building primarily for sale in the ordinary course of his trade or…
1Opinion of the Court
C. EDWIN RYMER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rymer v. Commissioner
Docket No. 16750-80.
United States Tax Court
T.C. Memo 1986-534; 1986 Tax Ct. Memo LEXIS 74; 52 T.C.M. (CCH) 964; T.C.M. (RIA) 86534;
November 4, 1986.
Petitioner, while working as an apartment building manager, bought an apartment building as a personal investment. Later, he lost his job and attempted to sell the apartment building. A potential buyer indicated interest in the building if petitioner could offer an adjacent parcel of land for sale along with the apartment building. Petitioner then…
2Cases cited27 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Malat v. RiddellSupreme Court of the United States · 1966
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
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