Knollwood Memorial Gardens v. Commissioner
United States Tax Court
1. Held: On the facts, payments made by petitioner to its "landshare holders" and deducted by it during the taxable years as the cost of land sold do not represent deductible land costs but rather nondeductible distributions made with respect to equity investment which such landshare holders had in petitioner. Sherwood Memorial Gardens, Inc., 42 T.C. 211 (1964), affd. 350 F. 2d 225 (C.A. 7, 1965), followed.
Read the full summary
1. Held: On the facts, payments made by petitioner to its "landshare holders" and deducted by it during the taxable years as the cost of land sold do not represent deductible land costs but rather nondeductible distributions made with respect to equity investment which such landshare holders had in petitioner. Sherwood Memorial Gardens, Inc., 42 T.C. 211 (1964), affd. 350 F. 2d 225 (C.A. 7, 1965), followed. Petitioner was not a tax-exempt cemetery company within the intendment of section 501(c)(13), I.R.C. 1954. 2. Held: Deficiencies and additions to tax for petitioner's fiscal year 1958…
1Opinion of the Court
Knollwood Memorial Gardens, Petitioner, v. Commissioner of Internal Revenue, Respondent
Knollwood Memorial Gardens v. Commissioner
Docket No. 2017-63
United States Tax Court
46 T.C. 764; 1966 U.S. Tax Ct. LEXIS 42;
September 28, 1966, Filed
Decision will be entered under Rule 50.
1. Held: On the facts, payments made by petitioner to its "landshare holders" and deducted by it during the taxable years as the cost of land sold do not represent deductible land costs but rather nondeductible distributions made with respect to equity investment which such landshare holders had in petitioner. Sherwood…
Also in this document: Concurrence.
2Cases cited27 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Commissioner v. ConnellySupreme Court of the United States · 1949
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
22 more not listed; retrieve them via the Exa API.