Harmston v. Commissioner
United States Tax Court
T, as buyer, entered into two contracts for the purchase of two orange groves. The groves were newly planted, and required 4 years of maintenance and care in order to become mature or established. The contract price was $ 4,500 an acre, payable at the rate of $ 1,125 per acre per year over a 4-year period. During the 4-year period the seller remained in possession and assumed full responsibility in the contracts to provide maintenance and care.
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T, as buyer, entered into two contracts for the purchase of two orange groves. The groves were newly planted, and required 4 years of maintenance and care in order to become mature or established. The contract price was $ 4,500 an acre, payable at the rate of $ 1,125 per acre per year over a 4-year period. During the 4-year period the seller remained in possession and assumed full responsibility in the contracts to provide maintenance and care. The seller also retained legal title, paid the real estate taxes, and in general retained most of the burdens and benefits of ownership. Held, the…
1Opinion of the Court
Gordon J. Harmston and Alice C. Harmston, Petitioners v. Commissioner of Internal Revenue, Respondent
Harmston v. Commissioner
Docket No. 8374-71
United States Tax Court
61 T.C. 216; 1973 U.S. Tax Ct. LEXIS 23; 61 T.C. No. 24;
November 14, 1973, Filed
Decision will be entered for the respondent.
T, as buyer, entered into two contracts for the purchase of two orange groves. The groves were newly planted, and required 4 years of maintenance and care in order to become mature or established. The contract price was $ 4,500 an acre, payable at the rate of $ 1,125 per acre per year over a 4-year period.…
2Cases cited21 opinions
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
- Merrill v. CommissionerUnited States Tax Court · 1963
- Commissioner of Internal Revenue v. SegallCourt of Appeals for the Sixth Circuit · 1940
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Clodfelter v. CommissionerUnited States Tax Court · 1967
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