Legal Opinion

Howard Hughes Co., LLC v. Comm'r

United States Tax Court

Decided June 2, 2014No. Docket Nos. 10539-11, 10565-11Published

Ps are in the residential land development business and develop land in and adjacent to Las Vegas, Nevada. Ps sell land to builders and, in some cases, individuals, who construct and sell houses. Ps generally sell land through bulk sales, pad sales, finished lot sales, and custom lot sales. In bulk sales, Ps develop raw land into villages and sell an entire village to a builder. Ps do not otherwise develop the sold village.

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Ps are in the residential land development business and develop land in and adjacent to Las Vegas, Nevada. Ps sell land to builders and, in some cases, individuals, who construct and sell houses. Ps generally sell land through bulk sales, pad sales, finished lot sales, and custom lot sales. In bulk sales, Ps develop raw land into villages and sell an entire village to a builder. Ps do not otherwise develop the sold village. In pad sales, Ps develop villages into parcels and sell the parcels to builders. Ps do not develop within the sold parcels. In finished lot sales, Ps develop parcels into…

1Opinion of the Court

THE HOWARD HUGHES COMPANY, LLC, f.k.a. THE HOWARD HUGHES CORPORATION, AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent;

HOWARD HUGHES PROPERTIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Howard Hughes Co., LLC v. Comm'r

Docket Nos. 10539-11, 10565-11.

United States Tax Court

142 T.C. 355; 2014 U.S. Tax Ct. LEXIS 21; 142 T.C. No. 20;

June 2, 2014, Filed

Decisions will be entered for respondent.

Ps are in the residential land development business and develop land in and adjacent to Las Vegas, Nevada. Ps sell land to builders and, in some cases,…

2Cases cited25 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. Bingler v. JohnsonSupreme Court of the United States · 1969
  4. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  5. Commissioner v. HansenSupreme Court of the United States · 1959

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