Holladay v. Commissioner
United States Tax Court
Petitioner formed a joint venture with Babcock Co. to complete development of an apartment complex. Babcock Co. previously had obtained the land and begun construction. Petitioner agreed to provide an equity contribution of $ 750,000 and loans up to $ 1 million. Each party agreed to share equally the burden of providing whatever additional financing might be necessary.
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Petitioner formed a joint venture with Babcock Co. to complete development of an apartment complex. Babcock Co. previously had obtained the land and begun construction. Petitioner agreed to provide an equity contribution of $ 750,000 and loans up to $ 1 million. Each party agreed to share equally the burden of providing whatever additional financing might be necessary. With regard to equity cash distributions, the parties agreed to split the first $ 100,000, to distribute the next $ 150,000 to Babcock Co., and thereafter to share equally. Notwithstanding this nearly equal division of economic…
1Opinion of the Court
Durand A. Holladay and Blanche F. Holladay, Petitioners v. Commissioner of Internal Revenue, Respondent
Holladay v. Commissioner
Docket No. 6781-75
United States Tax Court
72 T.C. 571; 1979 U.S. Tax Ct. LEXIS 97; 72 T.C. No. 51;
June 25, 1979, Filed
Decision will be entered under Rule 155.
Petitioner formed a joint venture with Babcock Co. to complete development of an apartment complex. Babcock Co. previously had obtained the land and begun construction. Petitioner agreed to provide an equity contribution of $ 750,000 and loans up to $ 1 million. Each party agreed to share equally the burden of…
Also in this document: Concurrence · Tannenwald; Concurrence · Simpson; Dissent.
2Cases cited16 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Karl F. Knetsch and Eva Fay Knetsch v. The United StatesUnited States Court of Claims · 1965
- Van Raden v. CommissionerUnited States Tax Court · 1979
- E. Keith Owens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1977
- Norman and Arlene Rodman, Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1976
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