Ellison v. Commissioner
United States Tax Court
Partnership A purchased an apartment complex, with the "benefits and obligations" of ownership passing as of July 1, 1977. The sales agreement provided that, in addition to the stated purchase price and certain other payments, the seller was to receive the first $ 500,000 of rents from the complex after the sale.
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Partnership A purchased an apartment complex, with the "benefits and obligations" of ownership passing as of July 1, 1977. The sales agreement provided that, in addition to the stated purchase price and certain other payments, the seller was to receive the first $ 500,000 of rents from the complex after the sale. In a similar transaction, partnership C purchased an apartment complex, with the "benefits and obligations" of ownership passing as of Nov. 1, 1977. In addition to the stated purchase price, the sellers were to receive the first $ 50,000 of rents from the complex in each of the first…
1Opinion of the Court
Roger M. Ellison and Rosemary J. Ellison, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Ellison v. Commissioner
Docket Nos. 14449-81, 14450-81, 14770-81, 16211-81, 16319-81, 17552-81
United States Tax Court
80 T.C. 378; 1983 U.S. Tax Ct. LEXIS 116; 80 T.C. No. 13;
February 14, 1983, Filed
Decisions will be entered under Rule 155.
Partnership A purchased an apartment complex, with the "benefits and obligations" of ownership passing as of July 1, 1977. The sales agreement provided that, in addition to the stated purchase price and certain other payments, the seller was to…
2Cases cited28 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Corliss v. BowersSupreme Court of the United States · 1930
- Morgan v. CommissionerSupreme Court of the United States · 1940
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