Legal Opinion

Lomas Santa Fe, Inc. v. Commissioner

United States Tax Court

Decided July 9, 1980No. Docket No. 6578-77Published

As the first step in the development of a luxury residential community, X built a golf course and country club. The golf course and country club were to serve as a marketing tool for adjacent residential properties.

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As the first step in the development of a luxury residential community, X built a golf course and country club. The golf course and country club were to serve as a marketing tool for adjacent residential properties. To solve real estate title problems and to insulate X and its operations from the membership of the country club, X formed Y as a wholly owned subsidiary and transferred the assets of the golf course and country club to Y. Some assets were transferred outright, but some were transferred subject to a retained estate for 40 years in X. The estate for years was retained so that X…

1Opinion of the Court

Lomas Santa Fe, Inc., and Subsidiary Companies: Lomas Santa Fe Country Club, Norco Landscape & Maintenance Co., Petitioners v. Commissioner of Internal Revenue, Respondent

Lomas Santa Fe, Inc. v. Commissioner

Docket No. 6578-77

United States Tax Court

74 T.C. 662; 1980 U.S. Tax Ct. LEXIS 106;

July 9, 1980, Filed

Decision will be entered under Rule 155.

As the first step in the development of a luxury residential community, X built a golf course and country club. The golf course and country club were to serve as a marketing tool for adjacent residential properties. To solve real estate title problems…

2Cases cited36 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  5. Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932

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