Koch v. Commissioner
United States Tax Court
In 1973 and 1974, petitioners exchanged unencumbered parcels of real estate which they owned in fee simple for parcels of real estate which were subject to 99-year condominium leases. Held, the properties so exchanged are properties of a like kind within the meaning of sec. 1031(a), I.R.C. 1954, and no gain is recognized on the exchanges.
1Opinion of the Court
Featherston, Judge:
In this case,1 respondent determined deficiencies in petitioners’ Federal income tax for the years 1972, 1973, and 1974, as follows:
Petitioners 1972 1973 197k
Carl E. Koch and Paula Koch ... $24,601.09 $248,222.50 $417,808.50
Frederick W. Koch and Robin E. Koch (a.k.a. Robin E. Pruitt) ... 0 147,067.02 ' 0
William A. Bomberger and Garolyn L. Bomberger . 0 134,980.98 0
John J. Koch . 0 137,849.71 0
Other issues having been settled, the issues which remain for decision are as follows:(1) Whether petitioners’ exchanges in 1973 and 1974 of fee interests in real estate for fee…
2Cases cited24 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Morris Lipsitz, and Morris Lipsitz and Helen Lipsitz v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
- Biggs v. CommissionerUnited States Tax Court · 1978
- Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
- Jordan Marsh Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
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3Cited by41 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- William F. Sullivan and Rosemary C. Sullivan v. United StatesCourt of Appeals for the Third Circuit · 1980
- Norman J. And Beverly G. Magneson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Click v. CommissionerUnited States Tax Court · 1982
- DeCleene v. CommissionerUnited States Tax Court · 2000
36 more not listed; retrieve them via the Exa API.