Patel v. Comm'r
United States Tax Court
At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired Structures Program, where a property owner allows FCFRD to conduct live fire training exercises on his or her property.
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At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired Structures Program, where a property owner allows FCFRD to conduct live fire training exercises on his or her property. As part of the exercises, FCFRD destroys, by burning, the designated building on the owner's property. Within a few weeks of purchasing the Vienna property, Ps contacted FCFRD and obtained…
1Opinion of the Court
UPEN G. PATEL AND AVANTI D. PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Patel v. Comm'r
Docket No. 11694-09.
United States Tax Court
138 T.C. 395; 2012 U.S. Tax Ct. LEXIS 24; 138 T.C. No. 23;
June 27, 2012, Filed
An appropriate order will be issued, and decision will be entered under Rule 155.
At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired…
Also in this document: Dissent · Kerrigan; Dissent · Gale.
2Cases cited151 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Aquilino v. United StatesSupreme Court of the United States · 1960
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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