Hunt v. Commissioner
United States Tax Court
On Mar. 16, 1973, petitioner-husbands executed a contract to sell KEV, an apartment complex, to S, a corporation, for $ 2,701,000. On Mar. 26, 1973, petitioner-husbands had outstanding debt against KEV of $ 1,963,222.69, and a combined basis in KEV of $ 1,576,410.29. On Mar. 26, 1973, they executed a warranty deed conveying KEV to S, in which they covenanted to continue to pay installments on the outstanding debt; S's president executed (1) a vendor's lien note (wraparound…
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On Mar. 16, 1973, petitioner-husbands executed a contract to sell KEV, an apartment complex, to S, a corporation, for $ 2,701,000. On Mar. 26, 1973, petitioner-husbands had outstanding debt against KEV of $ 1,963,222.69, and a combined basis in KEV of $ 1,576,410.29. On Mar. 26, 1973, they executed a warranty deed conveying KEV to S, in which they covenanted to continue to pay installments on the outstanding debt; S's president executed (1) a vendor's lien note (wraparound note) for $ 2,541,000, providing for monthly installment payments beginning May 1, 1973, and (2) a purchase money note…
1Opinion of the Court
Chabot, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioners as follows:
Docket No. Petitioners Year Deficiency
10890-78 D. A. Hunt and Estate of Altha Hunt (D. A. Hunt, surviving spouse) 1973 $7,941.89
10912-78 Dewey A. Hunt, Jr., and Marian C. Hunt 1973 12,267.85
10913-78 William J. Hunt and Betty J. Hunt 1973 12,678.42 1974 1,244.67
These cases have been consolidated for trial, briefs, and opinion. After concessions by petitioners,2 the issue for decision is whether, under section 453 on the sale of an apartment complex, (1) the amount by which each…
2Cases cited15 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Burnet v. S. & L. Building Corp.Supreme Court of the United States · 1933
- Stonecrest Corp. v. CommissionerUnited States Tax Court · 1955
- Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. HaserotCourt of Appeals for the Sixth Circuit · 1968
10 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Brown-Forman Corp. v. CommissionerUnited States Tax Court · 1990
- Professional Equities v. CommissionerUnited States Tax Court · 1987
- Sallies v. CommissionerUnited States Tax Court · 1984
- Gershman Family Foundation v. CommissionerUnited States Tax Court · 1984
- Owen v. CommissionerUnited States Tax Court · 1987
10 more not listed; retrieve them via the Exa API.