Perelman v. Commissioner
United States Tax Court
In the latter part of 1950, Howard H. Perelman and others formed a partnership to sell improved real estate. In 1951 and 1952, certain parcels of real estate were sold. In each case, the purchaser made a cash downpayment and gave a land contract to evidence the remaining balance of the purchase price.
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In the latter part of 1950, Howard H. Perelman and others formed a partnership to sell improved real estate. In 1951 and 1952, certain parcels of real estate were sold. In each case, the purchaser made a cash downpayment and gave a land contract to evidence the remaining balance of the purchase price. The income from the foregoing sales was reported on the basis that the receipts therefrom did not constitute taxable income until the cost or adjusted basis of the property had first been recovered. For the taxable years 1951 through 1956, petitioners reported their income in the foregoing…
1Opinion of the Court
OPINION
In their petition, petitioners alleged that the gain from the sale of the Gaines, Clark, and Gregory properties was not includable in their income for the respective years 1957 and 1958 because respondent had changed their method of accounting. On brief petitioners took somewhat of an alternative approach and contended that the gain from the respective properties should have been reported in 1951 and 1952 wlien the sales were made. Petitioners argue that they received, in the year of sale, casli and property equal to the total sales price of each piece of property and that this amount…
2Cases cited14 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Pursell v. CommissionerUnited States Tax Court · 1962
- Commissioner of Internal Revenue v. DwyerCourt of Appeals for the Second Circuit · 1953
- Johnston v. CommissionerUnited States Tax Court · 1950
- Pacific Coast Biscuit Co. v. CommissionerUnited States Board of Tax Appeals · 1935
9 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- H. F. Campbell Co. v. CommissionerUnited States Tax Court · 1969
- H. F. Campbell Company (Formerly H. F. Campbell Construction Company) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1971
- Herbert S. Witte v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1975
- Heller Trust v. CommissionerCourt of Appeals for the Ninth Circuit · 1967
- City Gas Co. v. CommissionerUnited States Tax Court · 1984
6 more not listed; retrieve them via the Exa API.