Cusack v. Commissioner
United States Tax Court
Sec. 1033, I.R.C. 1954 -- Purchase of Similar Property. -- Petitioners, in order to acquire investment property similar to property involuntarily converted by condemnation in 1959, executed as buyers a "Deed and Agreement of Sale" on Dec. 21, 1960, whereby sellers granted to them certain unimproved lands in California for $ 195,879, with $ 5,000 paid on execution and $ 190,879 to be paid by July 1, 1961, with interest.
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Sec. 1033, I.R.C. 1954 -- Purchase of Similar Property. -- Petitioners, in order to acquire investment property similar to property involuntarily converted by condemnation in 1959, executed as buyers a "Deed and Agreement of Sale" on Dec. 21, 1960, whereby sellers granted to them certain unimproved lands in California for $ 195,879, with $ 5,000 paid on execution and $ 190,879 to be paid by July 1, 1961, with interest. It was provided that if access road or water supply was not made available to the property by sellers by July 1, 1961, buyers had the option to reconvey and to recover all sums…
1Opinion of the Court
William B. Cusack and Eileen M. Cusack, Petitioners v. Commissioner of Internal Revenue, Respondent
Cusack v. Commissioner
Docket No. 1041-65
United States Tax Court
48 T.C. 156; 1967 U.S. Tax Ct. LEXIS 108;
May 15, 1967, Filed
Decision will be entered under Rule 50.
Sec. 1033, I.R.C. 1954 -- Purchase of Similar Property. -- Petitioners, in order to acquire investment property similar to property involuntarily converted by condemnation in 1959, executed as buyers a "Deed and Agreement of Sale" on Dec. 21, 1960, whereby sellers granted to them certain unimproved lands in California for $ 195,879,…
2Cases cited5 opinions
- Lucile McAulay Filippini, as of the Last Will and Testament of Carra McAulay Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1963
- Gaynor News Co. v. CommissionerUnited States Tax Court · 1954
- John Richard Corp. v. CommissionerUnited States Tax Court · 1966
- Johnson v. CommissionerUnited States Tax Court · 1965
- Cusack v. CommissionerUnited States Tax Court · 1967