Legal Opinion

Bailey v. Commissioner

United States Tax Court

Decided May 18, 1987No. Docket No. 21107-85Published

P bought property in an area subject to an urban renewal project. As a participant in a program that was part of the project, P received a facade grant. According to the terms of the grant, the city's urban renewal agency (URA) agreed to restore the facade on P's building and P promised to rehabilitate the interior of the building and to maintain the facade.

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P bought property in an area subject to an urban renewal project. As a participant in a program that was part of the project, P received a facade grant. According to the terms of the grant, the city's urban renewal agency (URA) agreed to restore the facade on P's building and P promised to rehabilitate the interior of the building and to maintain the facade. The URA contracted for the facade rehabilitation and was the party that chose the contractor, negotiated the terms of the contract, and paid the contractor directly for the work. P was not permitted to alter the facade in any way without…

1Opinion of the Court

James Bailey, Petitioner v. Commissioner of Internal Revenue, Respondent

Bailey v. Commissioner

Docket No. 21107-85

United States Tax Court

88 T.C. 1293; 1987 U.S. Tax Ct. LEXIS 72; 88 T.C. No. 72;

May 18, 1987. May 18, 1987, Filed

Decision will be entered under Rule 155.

P bought property in an area subject to an urban renewal project. As a participant in a program that was part of the project, P received a facade grant. According to the terms of the grant, the city's urban renewal agency (URA) agreed to restore the facade on P's building and P promised to rehabilitate the interior of the building…

2Cases cited10 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Lilly v. CommissionerSupreme Court of the United States · 1952
  3. Helvering v. BruunSupreme Court of the United States · 1940
  4. Graff v. CommissionerUnited States Tax Court · 1980
  5. Alvin v. Graff v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1982

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