Oliver v. Commissioner
United States Tax Court
In 1946 Horace E. Oliver contributed 40 lots to a partnership in which he owned a 50 per cent interest. The partnership built houses on the lots and sold them in the ordinary course of its business during 1946 and 1947. The partners treated the transfer of the lots as a sale to the partnership. They agreed that the F.H.A. appraisal value of the lots should be credited to Oliver's account.
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In 1946 Horace E. Oliver contributed 40 lots to a partnership in which he owned a 50 per cent interest. The partnership built houses on the lots and sold them in the ordinary course of its business during 1946 and 1947. The partners treated the transfer of the lots as a sale to the partnership. They agreed that the F.H.A. appraisal value of the lots should be credited to Oliver's account. Petitioners reported the excess of such value over the cost of the lots as a long-term capital gain. The partnership computed gain on the sale of the houses and lots using the F.H.A. appraisal value as its…
1Opinion of the Court
Horace E. Oliver v. Commissioner. Kathleen Oliver v. Commissioner.
Oliver v. Commissioner
Docket Nos. 41084, 41085.
United States Tax Court
1954 Tax Ct. Memo LEXIS 312; 13 T.C.M. (CCH) 67; T.C.M. (RIA) 54034;
January 29, 1954
In 1946 Horace E. Oliver contributed 40 lots to a partnership in which he owned a 50 per cent interest. The partnership built houses on the lots and sold them in the ordinary course of its business during 1946 and 1947. The partners treated the transfer of the lots as a sale to the partnership. They agreed that the F.H.A. appraisal value of the lots should be credited to…
2Cited by2 opinions
- Otey v. CommissionerUnited States Tax Court · 1978
- Otey v. CommissionerUnited States Tax Court · 1978