Legal Opinion

Mitchell v. Commissioner

United States Tax Court

Decided November 15, 1966No. Docket No. 1141-65Published

In June 1959 petitioner George W. Mitchell purchased at public auction the property in Baltimore, Md., known as Old Sinai Hospital for the price of $ 708,000. Thereafter, petitioner entered into a joint venture with two individuals (both now deceased) whereby title to the purchased property was taken in the names of the three joint venturers, with petitioner having a 40-percent interest and the other two a 40-percent and 20-percent interest, respectively.

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In June 1959 petitioner George W. Mitchell purchased at public auction the property in Baltimore, Md., known as Old Sinai Hospital for the price of $ 708,000. Thereafter, petitioner entered into a joint venture with two individuals (both now deceased) whereby title to the purchased property was taken in the names of the three joint venturers, with petitioner having a 40-percent interest and the other two a 40-percent and 20-percent interest, respectively. Settlement on the property was held on Jan. 29, 1960. The property was so held until the year 1961 when it was sold in two portions for a…

1Opinion of the Court

George W. Mitchell and Marie J. Mitchell, Petitioners v. Commissioner of Internal Revenue, Respondent

Mitchell v. Commissioner

Docket No. 1141-65

United States Tax Court

47 T.C. 120; 1966 U.S. Tax Ct. LEXIS 23;

November 15, 1966, Filed

Decision will be entered under Rule 50.

In June 1959 petitioner George W. Mitchell purchased at public auction the property in Baltimore, Md., known as Old Sinai Hospital for the price of $ 708,000. Thereafter, petitioner entered into a joint venture with two individuals (both now deceased) whereby title to the purchased property was taken in the names of the three…

2Cases cited17 opinions

  1. Malat v. RiddellSupreme Court of the United States · 1966
  2. Burnet v. ClarkSupreme Court of the United States · 1932
  3. Thrift v. CommissionerUnited States Tax Court · 1950
  4. Farley v. CommissionerUnited States Tax Court · 1946
  5. Robinson v. CommissionerUnited States Tax Court · 1943

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