Legal Opinion

Estate of Collins v. Commissioner

United States Tax Court

Decided October 30, 1958No. Docket No. 62264Published

Taxpayers were in the business of developing subdivisions of real estate and selling lots therein to builders. In developing the subdivisions here in question it was necessary for taxpayers to arrange and pay for a sewage disposal system servicing the residential units in order to induce people to buy lots therein.

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Taxpayers were in the business of developing subdivisions of real estate and selling lots therein to builders. In developing the subdivisions here in question it was necessary for taxpayers to arrange and pay for a sewage disposal system servicing the residential units in order to induce people to buy lots therein. By various conveyances, trust deeds, and agreements, the owners of the lots were given an equitable interest in the system, a corporation owned by taxpayers was given the right and duty to operate the system for annual charges to be paid by the lot owners which were abnormally low…

1Opinion of the Court

Estate of M. A. Collins, Deceased, Lila T. Collins, Administratrix, and Lila T. Collins, Individually, Petitioners, v. Commissioner of Internal Revenue, Respondent

Estate of Collins v. Commissioner

Docket No. 62264

United States Tax Court

31 T.C. 238; 1958 U.S. Tax Ct. LEXIS 47;

October 30, 1958, Filed

Decision will be entered under Rule 50.

Taxpayers were in the business of developing subdivisions of real estate and selling lots therein to builders. In developing the subdivisions here in question it was necessary for taxpayers to arrange and pay for a sewage disposal system servicing the…

Also in this document: Dissent.

2Cases cited3 opinions

  1. Colony, Inc. v. CommissionerUnited States Tax Court · 1956
  2. The Colony, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957
  3. Estate of Collins v. CommissionerUnited States Tax Court · 1958

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