Elrod v. Commissioner
United States Tax Court
Petitioner transferred land pursuant to an optional sales contract, as amended, to be developed in part as a regional shopping center. The terms of the contract were ambiguous and petitioner offered parol evidence that the contract constituted an option agreement rather than a completed sale. Petitioner orally agreed that his brother and sister each were entitled to share in the net profits realized from his real estate activities.
Read the full summary
Petitioner transferred land pursuant to an optional sales contract, as amended, to be developed in part as a regional shopping center. The terms of the contract were ambiguous and petitioner offered parol evidence that the contract constituted an option agreement rather than a completed sale. Petitioner orally agreed that his brother and sister each were entitled to share in the net profits realized from his real estate activities. Petitioner deducted consulting fees paid to them with respect to the land transferred pursuant to the optional sales contract, as amended, as expenses incurred…
1Opinion of the Court
Johnie Vaden Elrod, Petitioner v. Commissioner of Internal Revenue, Respondent
Elrod v. Commissioner
Docket No. 17669-83
United States Tax Court
87 T.C. 1046; 1986 U.S. Tax Ct. LEXIS 21; 87 T.C. No. 67;
November 12, 1986, Filed
Decision will be entered under Rule 155.
Petitioner transferred land pursuant to an optional sales contract, as amended, to be developed in part as a regional shopping center. The terms of the contract were ambiguous and petitioner offered parol evidence that the contract constituted an option agreement rather than a completed sale. Petitioner orally agreed that his brother…
2Cases cited40 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. CulbertsonSupreme Court of the United States · 1949
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
35 more not listed; retrieve them via the Exa API.