Legal Opinion

Estate of Bartell v. Comm'r

United States Tax Court

Decided August 10, 2016No. Docket Nos. 22709-05, 22829-05, 22891-05PublishedCited by 1 opinion

In 1999, BD, a drugstore chain, entered into an agreement to purchase property L from a third party. In anticipation of structuring an exchange transaction under I.R.C. sec. 1031 to facilitate acquisition of L, BD later assigned its rights in the purchase agreement to third-party exchange facilitator EPC and entered a further agreement with EPC.

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In 1999, BD, a drugstore chain, entered into an agreement to purchase property L from a third party. In anticipation of structuring an exchange transaction under I.R.C. sec. 1031 to facilitate acquisition of L, BD later assigned its rights in the purchase agreement to third-party exchange facilitator EPC and entered a further agreement with EPC. That second agreement provided for EPC to purchase L and for BD to have a right to acquire L from EPC for a stated period and price. EPC so purchased L on August 1, 2000, with bank financing guaranteed by BD, acquiring title to L at that time. BD then…

1Opinion of the Court

ESTATE OF GEORGE H. BARTELL, JR. DECEASED, GEORGE DAVID BARTELL AND JEAN LOUISE BARTELL BARBER, CO-PERSONAL REPRESENTATIVES AND ESTATE OF ELIZABETH BARTELL, DECEASED, GEORGE DAVID BARTELL AND JEAN LOUISE BARTELL BARBER, CO-PERSONAL REPRESENTATIVES, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Bartell v. Comm'r

Docket Nos. 22709-05, 22829-05, 22891-05

United States Tax Court

147 T.C. 140; 2016 U.S. Tax Ct. LEXIS 21; 147 T.C. No. 5;

August 10, 2016, Filed

Decisions will be entered for petitioners.

In 1999, BD, a drugstore chain, entered into an agreement to purchase…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  4. Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
  5. New York v. MacLaySupreme Court of the United States · 1933

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3Cited by1 opinion

  1. Barlow, Jr. v. District of ColumbiaDistrict of Columbia Court of Appeals · 2026

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