Legal Opinion

Haynsworth v. Commissioner

United States Tax Court

Decided August 22, 1977No. Docket No. 5501-75PublishedCited by 10 opinions

In 1959, a partnership of which petitioner-husband was a member acquired a piece of land for subdivision purposes, obtained an estimate of the costs of developing it, and began development and sales of lots from the subdivision. The partnership created a reserve account in the amount of the estimated costs and debited that account with development costs actually paid.

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In 1959, a partnership of which petitioner-husband was a member acquired a piece of land for subdivision purposes, obtained an estimate of the costs of developing it, and began development and sales of lots from the subdivision. The partnership created a reserve account in the amount of the estimated costs and debited that account with development costs actually paid. As each lot was sold, the partnership deducted a proportionate part of the land costs as well as a proportionate part of the estimated development costs from the selling price in computing the gross profit from the sale. By Nov.…

1Opinion of the Court

Featherston, Judge:

Respondent determined a deficiency of $7,993.52 in petitioners’ Federal income tax for 1972. The issue for decision is whether petitioners realized ordinary income in 1972 in the amount of the distributive share of the unused portion of a reserve for estimated subdivision development expenses which had been deducted by a partnership, of which petitioner Robert F. Haynsworth was a member, in computing its gain in prior years on the sale of lots from the subdivision.

FINDINGS OF FACT

Petitioners Robert F. Haynsworth (hereinafter Haynsworth) and Hazel Haynsworth, husband and…

2Cases cited25 opinions

  1. Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
  2. Colony, Inc. v. CommissionerUnited States Tax Court · 1956
  3. Mayfair Minerals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
  4. Schuster's Express, Inc. v. CommissionerUnited States Tax Court · 1976
  5. The Colony, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957

20 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
  2. W. C. & A. N. Miller Dev. Co. v. CommissionerUnited States Tax Court · 1983
  3. Hutchinson v. CommissionerUnited States Tax Court · 2001
  4. Haynsworth v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
  5. David C. Hutchinson v. CommissionerUnited States Tax Court · 2001

5 more not listed; retrieve them via the Exa API.

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