Legal Opinion

Ebben v. Commissioner

United States Tax Court

Decided April 11, 1983No. Docket Nos. 8473-77, 7158-78, 2765-80, 13766-80, 18516-80, 1838-81Unpublished

Held: the fair market value of real property subject to a nonrecourse indebtedness which a partnership contributed to a charitable organization in 1973 determined.

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Held: the fair market value of real property subject to a nonrecourse indebtedness which a partnership contributed to a charitable organization in 1973 determined. Held further: the gift of the real property to the charity is a sale to the extent that the transfer was subject to the nonrecourse indebtedness and the partnership's adjusted basis for measuring gain on the bargain sale of the real property is to be determined under section 1011(b). Guest v. Commissioner,77 T.C. 9 (1981), followed.

1Opinion of the Court

LEO G. EBBEN AND DONNA W. EBBEN, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Ebben v. Commissioner

Docket Nos. 8473-77, 7158-78, 2765-80, 13766-80, 18516-80, 1838-81.

United States Tax Court

T.C. Memo 1983-200; 1983 Tax Ct. Memo LEXIS 594; 45 T.C.M. (CCH) 1283; T.C.M. (RIA) 83200;

April 11, 1983; As Amended May 11, 1983

Held: the fair market value of real property subject to a nonrecourse indebtedness which a partnership contributed to a charitable organization in 1973 determined.

Held further: the gift of the real property to the charity is a sale to the extent that the…

2Cases cited26 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. Estate of Horvath v. CommissionerUnited States Tax Court · 1973
  4. Kaplan v. CommissionerUnited States Tax Court · 1965
  5. Diedrich v. CommissionerSupreme Court of the United States · 1982

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