Wilson v. Commissioner
United States Tax Court
Developers and builders advanced funds to water companies and municipalities sufficient to finance extension of water facilities into new real estate projects. The water companies and municipalities gave the developers and builders "water refund contracts" in which the former promised to repay the latter a certain percentage of gross revenues for a specified number of years, or until the principal sum was repaid, whichever occurred first.
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Developers and builders advanced funds to water companies and municipalities sufficient to finance extension of water facilities into new real estate projects. The water companies and municipalities gave the developers and builders "water refund contracts" in which the former promised to repay the latter a certain percentage of gross revenues for a specified number of years, or until the principal sum was repaid, whichever occurred first. Although the water companies and municipalities kept records of the ownership status and payments, the contracts did not signify on their faces that such…
1Opinion of the Court
Ernest A. Wilson and Marjorie Wilson, Petitioners v. Commissioner of Internal Revenue, Respondent
Wilson v. Commissioner
Docket No. 2597-65
United States Tax Court
51 T.C. 723; 1969 U.S. Tax Ct. LEXIS 196;
February 5, 1969, Filed
Decision will be entered under Rule 50.
Developers and builders advanced funds to water companies and municipalities sufficient to finance extension of water facilities into new real estate projects. The water companies and municipalities gave the developers and builders "water refund contracts" in which the former promised to repay the latter a certain percentage of gross…
2Cases cited19 opinions
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
- McClain v. CommissionerSupreme Court of the United States · 1941
- Gerard v. HelveringCourt of Appeals for the Second Circuit · 1941
- Hudson v. CommissionerUnited States Tax Court · 1953
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