Ellison v. Commissioner
United States Tax Court
Partnership A purchased an apartment complex, with the "benefits and obligations" of ownership passing as of July 1, 1977. The sales agreement provided that, in addition to the stated purchase price and certain other payments, the seller was to receive the first $ 500,000 of rents from the complex after the sale.
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Partnership A purchased an apartment complex, with the "benefits and obligations" of ownership passing as of July 1, 1977. The sales agreement provided that, in addition to the stated purchase price and certain other payments, the seller was to receive the first $ 500,000 of rents from the complex after the sale. In a similar transaction, partnership C purchased an apartment complex, with the "benefits and obligations" of ownership passing as of Nov. 1, 1977. In addition to the stated purchase price, the sellers were to receive the first $ 50,000 of rents from the complex in each of the first…
1Opinion of the Court
OPINION
Featherston, Judge'.
Respondent determined that petitioners in these consolidated cases were liable for deficiencies in their Federal income taxes as follows:
Taxable
Petitioners year Deficiency
Roger M. Ellison and Rosemary J. Ellison . 1977 $10,504.00
Ross Rudolph and Nancy T. Rudolph . 1977 1,655.00
1978 6,110.00
Steven F. Lowe and Ruth W. Lowe . 1977 1,127.00
Vincent E. Webb and Carol A. Webb . 1977 3,394.00
Robert M. Elder and Irene B. Elder . 1977 12,279.38
Stanley F. Handel and Carolyn H. Handel 1975 12,894.33
1976 16,027.87
1977 26,224.11
After concessions by the parties, the only issue…
2Cases cited27 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Corliss v. BowersSupreme Court of the United States · 1930
- Morgan v. CommissionerSupreme Court of the United States · 1940
22 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Elrod v. CommissionerUnited States Tax Court · 1986
- Ansan Tool & Mfg. Co. v. CommissionerUnited States Tax Court · 1992
- Ellison v. CommissionerUnited States Tax Court · 1983
- Elrod v. CommissionerUnited States Tax Court · 1986
- Grossman v. CommissionerUnited States Tax Court · 1988
2 more not listed; retrieve them via the Exa API.