Legal Opinion

Upen G. Patel and Avanti D. Patel v. Commissioner

United States Tax Court

Decided June 27, 2012No. Docket 11694-09Unknown

1Opinion of the Court

UPEN G. PATEL AND AVANTI D. PATEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 11694–09. Filed June 27, 2012. At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired Structures Program, where a property owner allows FCFRD to conduct live fire training exercises on his or her property. As part of the exercises, FCFRD destroys, by burning, the…

2Cases cited145 opinions

  1. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  2. Aquilino v. United StatesSupreme Court of the United States · 1960
  3. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  4. Morgan v. CommissionerSupreme Court of the United States · 1940
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

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