Mangurian v. Commissioner
United States Tax Court
Petitioner organized a corporation to develop residential property in Florida. In the case of the cooperative apartment developments, petitioner acquired the land, obtained the required financing and entered into a 99-year ground lease with the corporation. The corporation undertook to construct and sell the units, subject to the ground lease. In the case of the condominium apartment developments, petitioner sold part of the land to the corporation for a cash consideration.
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Petitioner organized a corporation to develop residential property in Florida. In the case of the cooperative apartment developments, petitioner acquired the land, obtained the required financing and entered into a 99-year ground lease with the corporation. The corporation undertook to construct and sell the units, subject to the ground lease. In the case of the condominium apartment developments, petitioner sold part of the land to the corporation for a cash consideration. Petitioner thereupon erected so-called "recreational facilities" on the remainder of the land. Petitioner entered into a…
1Opinion of the Court
HARRY T. MANGURIAN, JR. and DOROTHY J. MANGURIAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; DREXEL PROPERTIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mangurian v. Commissioner
Docket Nos. 3709-75, 3710-75.
United States Tax Court
T.C. Memo 1979-91; 1979 Tax Ct. Memo LEXIS 442; 38 T.C.M. (CCH) 366; T.C.M. (RIA) 79091;
March 15, 1979, Filed
Petitioner organized a corporation to develop residential property in Florida. In the case of the cooperative apartment developments, petitioner acquired the land, obtained the required financing and entered into a…
2Cases cited12 opinions
- Palmer v. CommissionerSupreme Court of the United States · 1937
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- Avila South Condominium Ass'n, Inc. v. Kappa Corp.Supreme Court of Florida · 1977
- Welsh Homes, Incorporated, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1960
- Weish Homes, Inc. v. CommissionerUnited States Tax Court · 1959
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3Cited by2 opinions
- August Urbanek and Estate of Irene Urbanek, Deceased, August Urbanek, Personal Representative v. The United StatesCourt of Appeals for the Federal Circuit · 1984
- August Urbanek and Estate of Irene Urbanek, Deceased, August Urbanek, Personal Representative v. The United StatesCourt of Appeals for the Federal Circuit · 1984