Brown v. Commissioner
United States Tax Court
T entered into two contracts to purchase separate undeveloped tracts of land. In each instance the contract of sale provided for conveyance of the property to a trustee. The trust agreement recited that it was the intention of the buyer to subdivide the property. The trustee undertook to advance funds for development of the property, and the sellers subordinated their liens for the unpaid purchase price to the trustee.
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T entered into two contracts to purchase separate undeveloped tracts of land. In each instance the contract of sale provided for conveyance of the property to a trustee. The trust agreement recited that it was the intention of the buyer to subdivide the property. The trustee undertook to advance funds for development of the property, and the sellers subordinated their liens for the unpaid purchase price to the trustee. Provision was made for delivery of deeds to T by the trustee of portions of the properties selected by T in proportion to payment of the purchase price and repayment of…
1Opinion of the Court
Royce W. Brown and Patty L. Brown, Petitioners v. Commissioner of Internal Revenue, Respondent
Brown v. Commissioner
Docket No. 2841-68
United States Tax Court
54 T.C. 1475; 1970 U.S. Tax Ct. LEXIS 97;
July 14, 1970, Filed
Decision will be entered for the respondent.
T entered into two contracts to purchase separate undeveloped tracts of land. In each instance the contract of sale provided for conveyance of the property to a trustee. The trust agreement recited that it was the intention of the buyer to subdivide the property. The trustee undertook to advance funds for development of the property,…
2Cases cited20 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Malat v. RiddellSupreme Court of the United States · 1966
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Burnet v. ClarkSupreme Court of the United States · 1932
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