Legal Opinion
Blackstone Realty Company v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 12, 1968No. 24381_1PublishedCited by 20 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
This appeal presents the question of whether the Commissioner of Internal Revenue is bound by a taxpayer’s unilateral valuations of the component parts of a sale. The taxpayer, having sold a leasehold and appurtenant improvements to a buyer concerned only with the aggregate price, seeks to establish its own fragmented valuations in order to receive the tax benefits granted to installment sales through Section 453 of the Code. The Commissioner and the Tax Court rejected such valuations and refused to allow the tax benefits. We affirm.
The factual nature of this case…
2Cases cited14 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. TowerSupreme Court of the United States · 1946
- Bolen Webb and Cornelia Webb v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Albert Gordon MacRae and Sheila MacRae v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
9 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Redwing Carriers, Inc. v. TomlinsonCourt of Appeals for the Fifth Circuit · 1968
- Waterman Steamship Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Edward T. And Isabel J. Lysek v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- J. E. Casner and Una Casner v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Stanley G. Curtis, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1980
15 more not listed; retrieve them via the Exa API.