Legal Opinion

Greene v. Commissioner

United States Tax Court

Decided July 11, 1978No. Docket Nos. 5972-77, 5973-77, 5975-77, 5976-77, 5977-77, 5978-77, 5979-77, 5982-77, 5983-77, 5988-77, 6187-77PublishedCited by 1 opinion

The corporation acquired land on which it intended to build a motel. Although the land was acquired with the intent to demolish the buildings situated thereon, it was acquired under conditions which permitted the occupants of the dwelling to remain until the motel construction progressed to a point which required their removal.

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The corporation acquired land on which it intended to build a motel. Although the land was acquired with the intent to demolish the buildings situated thereon, it was acquired under conditions which permitted the occupants of the dwelling to remain until the motel construction progressed to a point which required their removal. The corporation reported gross rents of $ 13,347.42 for its taxable year 1972. Held: The rents did not constitute "proceeds from demolition" which, properly accounted for, would reduce the corporation's basis in the land. No meritorious grounds for deciding that the…

1Opinion of the Court

OPINION

Bruce, Judge:

Respondent determined deficiencies in the Federal income taxes of the petitioners in these consolidated cases as follows:

Docket No. Year Deficiency

5972-77. 1973 $2,437.00 1974 8,088.00

5973-77 10,582.19 1,131.97 1 — * to to -3 -ci ^ CO

5975-77. 1971 1,116.31 1972 3,697.65 1973 4,580.57 1974 7,984.43

5976-77. 1973 1,402.12

5977-77. 1972 3,899.08 1973 8,649.55 1974 13,784.29

5978-77. 1971 10,989.00 1972 7,352.00 1973 13,882.00 1974 1,329.00

5979-77. 1971 1,212.00 1972 6,462.00 1973 9,328.00 1974 8,843.00

5982-77. 1973 3,790.00 1974 13,947.00

5983-77. 1972 4,075.91

5988-77. 1972…

2Cases cited3 opinions

  1. Hillside Nat'l Bank v. CommissionerUnited States Tax Court · 1961
  2. Llewellyn v. CommissionerUnited States Tax Court · 1978
  3. Osborne v. CommissionerUnited States Tax Court · 1970

3Cited by1 opinion

  1. Greene v. CommissionerUnited States Tax Court · 1978

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