Estate of Wiggins v. Commissioner
United States Tax Court
Held, under the facts and circumstances, contracts for deed received by the developer of a "red flag" subdivision on the sale of lots had no ascertainable fair market value and petitioner is entitled to report the transactions on the cost recovery method.
1Opinion of the Court
Drennen, Judge:
Respondent determined the following deficiencies in petitioners’ income tax:
Year Deficiency Year Deficiency
1963. $14,683.44 1966 . $71,399.37
1964 . 27,082.61 1967 . 44,465.66
1965 . 84,128.94
The issues presented to us for our resolution are the following:(1) Whether petitioners may report the gain on the sale of subdivision lots under the cost recovery method of accounting.(a) Whether contracts for deed received as partial consideration for the sale of subdivision lots have an ascertainable fair market value as of the date of the transactions.(2) Even if the contracts for deed…
2Cases cited10 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- United States v. DavisSupreme Court of the United States · 1962
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- United Aniline Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
- McShain v. CommissionerUnited States Tax Court · 1979
5 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Major Realty Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Simmonds Precision Prods. v. Comm'rUnited States Tax Court · 1980
- Fisher v. United StatesUnited States Court of Federal Claims · 2008
- Estate of Silverman v. CommissionerUnited States Tax Court · 1992
- Royster v. CommissionerUnited States Tax Court · 1985
8 more not listed; retrieve them via the Exa API.