Gulfstream Land & Development Corp. v. Commissioner
United States Tax Court
Gulfstream's wholly owned subsidiary, Gulfstream Republic, owned a 50-percent interest in one joint venture; Gulfstream's wholly owned subsidiary, Gulfstream University, owned a 50-percent interest in another joint venture. Both joint ventures were formed to develop and improve land, to build homes on the land, and to sell the homes.
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Gulfstream's wholly owned subsidiary, Gulfstream Republic, owned a 50-percent interest in one joint venture; Gulfstream's wholly owned subsidiary, Gulfstream University, owned a 50-percent interest in another joint venture. Both joint ventures were formed to develop and improve land, to build homes on the land, and to sell the homes. Gulfstream Republic exchanged its joint venture interest for that of Gulfstream University's coventurer, thereby making Gulfstream Republic and Gulfstream University coventurers in the same joint venture, each having a 50-percent interest therein. Respondent…
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioners for the taxable years ended September 30, 1973, and September 30, 1974, in the respective amounts of $272,354 and $2,183,413. We have this matter before us on petitioners’ motion for partial summary judgment.1
Two issues are presented:(1) Whether any material facts are in issue so as to preclude a decision on the substantive issue; and(2) Whether the exchange of an interest in one joint venture for an interest in another joint venture qualifies for nonrecognition treatment pursuant to section…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Weiss v. StearnSupreme Court of the United States · 1924
- Shiosaki v. CommissionerUnited States Tax Court · 1974
- Hoeme v. CommissionerUnited States Tax Court · 1974
7 more not listed; retrieve them via the Exa API.
3Cited by72 opinions
- Vallone v. CommissionerUnited States Tax Court · 1987
- Graf v. CommissionerUnited States Tax Court · 1983
- Casanova Co. v. CommissionerUnited States Tax Court · 1986
- Estate of Chenoweth v. CommissionerUnited States Tax Court · 1987
- Grant Creek Water Works, Ltd. v. CommissionerUnited States Tax Court · 1988
67 more not listed; retrieve them via the Exa API.