Legal Opinion
Norman J. And Beverly G. Magneson v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 20, 1985No. 84-7069PublishedCited by 27 opinions
1Opinion of the Court
BOOCHEVER, Circuit Judge:
We are faced in this case with an issue of first impression in the Courts of Appeals: whether property acquired in a like-kind exchange with the intention of contributing it to a partnership under Internal Revenue Code § 721 is “held” for investment within the meaning of Internal Revenue Code § 1031(a).
Petitioners Norman and Beverly Magne-son exchanged a fee interest in one piece of real estate for a fee interest in another. The same day they contributed the acquired real estate to a limited partnership in return for a general partnership interest. The Magnesons claim…
2Cases cited27 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Aquilino v. United StatesSupreme Court of the United States · 1960
- T. J. Starker v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Gulfstream Land & Development Corp. v. CommissionerUnited States Tax Court · 1979
- Biggs v. CommissionerUnited States Tax Court · 1978
22 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Joseph R. Bolker v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Vukasovich, Inc. v. Commissioner of Internal Revenue, Vukasovich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Graham v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- John M. Casper v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1986
- Christopher Roche Juanita Roche v. Lincoln Property Company Swib Investment Company, and Invesco InstitutionalCourt of Appeals for the Fourth Circuit · 2004
22 more not listed; retrieve them via the Exa API.