Legal Opinion

Guest v. Commissioner

United States Tax Court

Decided July 2, 1981No. Docket No. 8844-76Published

Guest contributed real properties subject to nonrecourse indebtednesses in excess of Guest's adjusted bases in the properties to the temple. The temple directed Guest to deed the properties to persons to whom the temple arranged to sell the properties. Held, Guest made a charitable gift of the properties to the temple. Held, further, the gift was complete in the year Guest conveyed deeds to the properties to the temple's purchasers.

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Guest contributed real properties subject to nonrecourse indebtednesses in excess of Guest's adjusted bases in the properties to the temple. The temple directed Guest to deed the properties to persons to whom the temple arranged to sell the properties. Held, Guest made a charitable gift of the properties to the temple. Held, further, the gift was complete in the year Guest conveyed deeds to the properties to the temple's purchasers. Held, further, the gift of the properties to the temple is a bargain sale to the extent the nonrecourse indebtednesses exceeded Guest's adjusted bases in the…

1Opinion of the Court

Winston F. C. Guest and Lucy C. Guest, Petitioners v. Commissioner of Internal Revenue, Respondent

Guest v. Commissioner

Docket No. 8844-76

United States Tax Court

77 T.C. 9; 1981 U.S. Tax Ct. LEXIS 102;

July 2, 1981, Filed

Decision will be entered under Rule 155.

Guest contributed real properties subject to nonrecourse indebtednesses in excess of Guest's adjusted bases in the properties to the temple. The temple directed Guest to deed the properties to persons to whom the temple arranged to sell the properties. Held, Guest made a charitable gift of the properties to the temple. Held, further, the…

2Cases cited37 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Commissioner v. BrownSupreme Court of the United States · 1965
  3. Helvering v. HammelSupreme Court of the United States · 1941
  4. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
  5. Taft v. BowersSupreme Court of the United States · 1929

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