Osterlund, Inc. v. Commissioner
United States Tax Court
Petitioner-corporation leased vacant land from a related partnership pursuant to a month-to-month lease. The partnership had purchased the land solely for petitioner's use. At the time of the purchase, it was anticipated that the land would be developed and ready for petitioner's use within 1 year.
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Petitioner-corporation leased vacant land from a related partnership pursuant to a month-to-month lease. The partnership had purchased the land solely for petitioner's use. At the time of the purchase, it was anticipated that the land would be developed and ready for petitioner's use within 1 year. Petitioner made payments to the partnership pursuant to the month-to-month lease even though unforeseen, adverse economic conditions made it impracticable to develop the land until after the years in question. Held, petitioner's payments to the partnership were rental payments that were required to…
1Opinion of the Court
OSTERLUND, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Osterlund, Inc. v. Commissioner
Docket No. 35570-83.
United States Tax Court
T.C. Memo 1987-40; 1987 Tax Ct. Memo LEXIS 40; 52 T.C.M. (CCH) 1451; T.C.M. (RIA) 87040;
January 20, 1987.
Petitioner-corporation leased vacant land from a related partnership pursuant to a month-to-month lease. The partnership had purchased the land solely for petitioner's use. At the time of the purchase, it was anticipated that the land would be developed and ready for petitioner's use within 1 year. Petitioner made payments to the partnership…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
- Place v. CommissionerUnited States Tax Court · 1951
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Hunt & Sons, Inc. v. Comm'rUnited States Tax Court · 2002