Frazee v. Commissioner
United States Tax Court
Ps transferred improved real property to their children on Oct. 7, 1985, receiving in exchange a promissory note in the principal sum of $ 380,000, bearing interest at 7 percent, and secured by a first deed of trust on the improved real property. 1. Held, the highest and best use of the improved real property was industrial use.
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Ps transferred improved real property to their children on Oct. 7, 1985, receiving in exchange a promissory note in the principal sum of $ 380,000, bearing interest at 7 percent, and secured by a first deed of trust on the improved real property. 1. Held, the highest and best use of the improved real property was industrial use. Held, further, the value of the property was $ 1 million, allocating $ 950,000 to the land and $ 50,000 to the improvements. 2. Held, further:Sec. 7872, I.R.C., provides the proper interest rate to discount the promissory note for gift tax purposes. Ballard v.…
1Opinion of the Court
Edwin H. Frazee and Mabel G. Frazee, Petitioners v. Commissioner of Internal Revenue, Respondent
Frazee v. Commissioner
Docket Nos. 27995-89, 27996-89
United States Tax Court
98 T.C. 554; 1992 U.S. Tax Ct. LEXIS 41; 98 T.C. No. 37;
May 4, 1992, Filed
Decisions will be entered under Rule 155.
Ps transferred improved real property to their children on Oct. 7, 1985, receiving in exchange a promissory note in the principal sum of $ 380,000, bearing interest at 7 percent, and secured by a first deed of trust on the improved real property.
1. Held, the highest and best use of the improved real property was…
2Cases cited40 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Rubin v. United StatesSupreme Court of the United States · 1981
- Olson v. United StatesSupreme Court of the United States · 1934
- Commissioner v. WemyssSupreme Court of the United States · 1945
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
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