Arkin v. Commissioner
United States Tax Court
In 1973, petitioner purchased a 5-percent interest in a Florida land trust which held as its only asset undeveloped real property subject to a nonrecourse mortgage. Under the land trust agreement, the investors as beneficiaries of the land trust had the right to control and manage the property, and to share in proceeds from its sale in accordance with their proportionate ownership interests.
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In 1973, petitioner purchased a 5-percent interest in a Florida land trust which held as its only asset undeveloped real property subject to a nonrecourse mortgage. Under the land trust agreement, the investors as beneficiaries of the land trust had the right to control and manage the property, and to share in proceeds from its sale in accordance with their proportionate ownership interests. In addition, the investors agreed to pay their proportionate shares of the mortgage, taxes, insurance, and trustee's fees. In 1974, petitioner notified the trustee of the land trust and each of the other…
1Opinion of the Court
Lester J. Arkin and Sandra Arkin, Petitioners v. Commissioner of Internal Revenue, Respondent
Arkin v. Commissioner
Docket No. 2946-78
United States Tax Court
76 T.C. 1048; 1981 U.S. Tax Ct. LEXIS 107;
June 25, 1981, Filed
Decision will be entered under Rule 155.
In 1973, petitioner purchased a 5-percent interest in a Florida land trust which held as its only asset undeveloped real property subject to a nonrecourse mortgage. Under the land trust agreement, the investors as beneficiaries of the land trust had the right to control and manage the property, and to share in proceeds from its sale in…
2Cases cited10 opinions
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Riss v. CommissionerUnited States Tax Court · 1971
- Strong v. CommissionerUnited States Tax Court · 1976
- Richard R. Riss, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
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