Legal Opinion

Thompson v. Commissioner

United States Tax Court

Decided September 21, 1976No. Docket Nos. 1164-70, 1330-70, 1336-70, 3015-70Published

1. Del Cerro Associates (DCA), a limited partnership, contracted to purchase certain land from Sunset International Petroleum Corp. (Sunset) for $ 1,456,000 in promissory notes. At the closing of the purchase DCA paid Sunset $ 350,000 in cash, which was designated as prepaid interest for 4 years on the purchase-money notes.

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1. Del Cerro Associates (DCA), a limited partnership, contracted to purchase certain land from Sunset International Petroleum Corp. (Sunset) for $ 1,456,000 in promissory notes. At the closing of the purchase DCA paid Sunset $ 350,000 in cash, which was designated as prepaid interest for 4 years on the purchase-money notes. Shortly thereafter, DCA granted Lion, a real estate broker wholly owned by Sunset, an exclusive and noncancellable right to improve and resell the property at a price of not less than $ 2,250,000. Held, the cash paid by DCA at the time of purchase of the property…

1Opinion of the Court

Audrey M. Thompson, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Thompson v. Commissioner

Docket Nos. 1164-70, 1330-70, 1336-70, 3015-70

United States Tax Court

66 T.C. 1024; 1976 U.S. Tax Ct. LEXIS 48;

September 21, 1976, Filed

Decisions will be entered under Rule 155.

1. Del Cerro Associates (DCA), a limited partnership, contracted to purchase certain land from Sunset International Petroleum Corp. (Sunset) for $ 1,456,000 in promissory notes. At the closing of the purchase DCA paid Sunset $ 350,000 in cash, which was designated as prepaid interest for 4 years on the…

2Cases cited19 opinions

  1. Knetsch v. United StatesSupreme Court of the United States · 1960
  2. Massachusetts Mutual Life Insurance v. United StatesSupreme Court of the United States · 1933
  3. Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
  4. Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
  5. Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947

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