Narver v. Commissioner
United States Tax Court
JRYA, a corporation, purchased a building and its underlying and adjacent real property for $ 650,000. JRYA immediately sold the building, which had a fair market value of not more than $ 412,000, to two limited partnerships, 7th P.A. and 11th P.A.
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JRYA, a corporation, purchased a building and its underlying and adjacent real property for $ 650,000. JRYA immediately sold the building, which had a fair market value of not more than $ 412,000, to two limited partnerships, 7th P.A. and 11th P.A. (in each of which JRYA was the sole general partner), for $ 1,800,000. The partnerships then leased the building to CMC, a wholly owned subsidiary of JRYA, for rent which exactly satisfied the partnerships' nonrecourse purchase obligations to JRYA. Held: The purchase price so far exceeded the fair market value of the building that the payments by…
1Opinion of the Court
Fay, Judge:
These consolidated cases were tried before Special Trial Judge Charles R. Johnston pursuant to Rules 180 and 182, Tax Court Rules of Practice and Procedure. His report was filed on October 12, 1979, and exceptions to the report were subsequently filed by the parties. The Court has duly considered those exceptions and has given appropriate weight to the findings of fact recommended by Special Trial Judge Johnston. See Rule 182(c) and (d), and the accompanying note, Tax Court Rules of Practice and Procedure, 60 T.C. 1057,1149-1150 (1973).
Respondent determined the following…
2Cases cited21 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. BrownSupreme Court of the United States · 1965
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
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3Cited by125 opinions
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Siegel v. CommissionerUnited States Tax Court · 1982
- Flowers v. CommissionerUnited States Tax Court · 1983
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