Winding River Ranch, Inc. v. Commissioner
United States Tax Court
Petitioner acquired 710 acres from its sole stockholder in 1956. A part of this, some 115 acres, had been laid out as a subdivision and some blocks had previously been sold. Petitioner contracted with a builder to transfer to the builder a parcel for home construction and to transfer successive parcels as the builder could pay for them with a certain acreage to be taken each year. In 1961 petitioner transferred to this builder a parcel for cash and notes.
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Petitioner acquired 710 acres from its sole stockholder in 1956. A part of this, some 115 acres, had been laid out as a subdivision and some blocks had previously been sold. Petitioner contracted with a builder to transfer to the builder a parcel for home construction and to transfer successive parcels as the builder could pay for them with a certain acreage to be taken each year. In 1961 petitioner transferred to this builder a parcel for cash and notes. In the same year petitioner took a single 30-day note in place of several existing notes and discounted the note at a bank. Held: (1)…
1Opinion of the Court
Winding River Ranch, Inc. v. Commissioner.
Winding River Ranch, Inc. v. Commissioner
Docket No. 5123-64.
United States Tax Court
T.C. Memo 1966-260; 1966 Tax Ct. Memo LEXIS 23; 25 T.C.M. (CCH) 1335; T.C.M. (RIA) 66260;
November 30, 1966
Petitioner acquired 710 acres from its sole stockholder in 1956. A part of this, some 115 acres, had been laid out as a subdivision and some blocks had previously been sold. Petitioner contracted with a builder to transfer to the builder a parcel for home construction and to transfer successive parcels as the builder could pay for them with a certain acreage to be…
2Cases cited6 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- East Coast Equipment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- Elmer v. CommissionerUnited States Board of Tax Appeals · 1931
- Alworth-Washburn Co. v. HelveringCourt of Appeals for the D.C. Circuit · 1933
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