Fraser v. Commissioner
United States Tax Court
Taxpayer was instrumental in acquiring certain property for development. Due to financial difficulties he was unable to participate in the partnership formed to develop the property. However, it was agreed that the taxpayer would have the option to participate in the development at a later date for a proportionate share of the original investment. Taxpayer subsequently sold this option to certain of the other partners.
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Taxpayer was instrumental in acquiring certain property for development. Due to financial difficulties he was unable to participate in the partnership formed to develop the property. However, it was agreed that the taxpayer would have the option to participate in the development at a later date for a proportionate share of the original investment. Taxpayer subsequently sold this option to certain of the other partners. Held, the transaction resulted in the sale or exchange of an option within the meaning of sec. 1234(a), I.R.C. 1954, on account of which the taxpayer realized a gain from the…
1Opinion of the Court
Robert D. Fraser, Petitioner v. Commissioner of Internal Revenue, Respondent
Fraser v. Commissioner
Docket No. 6366-72
United States Tax Court
64 T.C. 41; 1975 U.S. Tax Ct. LEXIS 164;
April 15, 1975, Filed
Decision will be entered for the petitioner.
Taxpayer was instrumental in acquiring certain property for development. Due to financial difficulties he was unable to participate in the partnership formed to develop the property. However, it was agreed that the taxpayer would have the option to participate in the development at a later date for a proportionate share of the original investment.…
2Cases cited15 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner of Internal Revenue v. Golonsky. Commissioner of Internal Revenue v. GoldCourt of Appeals for the Third Circuit · 1952
- Nat Holt and Blanche Holt, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Commissioner of Internal Revenue v. McCue Bros. & Drummond, IncCourt of Appeals for the Second Circuit · 1954
- Golonsky v. CommissionerUnited States Tax Court · 1951
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