Clodfelter v. Commissioner
United States Tax Court
During the taxable year the petitioners, acting in accordance with a plan previously negotiated with two corporations which owned interests in hotel properties, purchased the lessee interest in the 99-year leasehold of the Waldorf Hotel in Seattle; and then as of the same date, they sold said leasehold together with certain hotel furniture to one of said corporations, under a contract of conditional sale, for the total price of $ 700,000 of which part was paid in the year of…
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During the taxable year the petitioners, acting in accordance with a plan previously negotiated with two corporations which owned interests in hotel properties, purchased the lessee interest in the 99-year leasehold of the Waldorf Hotel in Seattle; and then as of the same date, they sold said leasehold together with certain hotel furniture to one of said corporations, under a contract of conditional sale, for the total price of $ 700,000 of which part was paid in the year of sale and the balance was to be paid in deferred installments. Held, that the transaction whereby petitioners sold the…
1Opinion of the Court
Pierce, Judge:
The Commissioner determined a deficiency of $219,590.50 in the income tax of the above-named petitioners for their taxable calendar year 1957.
The issues for decision are:(1) Where during the taxable year the petitioners, acting in accordance with a previously negotiated plan, purchased the lessee interest in the 99-year leasehold of the Waldorf Hotel in Seattle, and then forthwith sold said leasehold interest together with certain hotel furniture to a corporation under a contract of conditional sale, for the total price of $700,000 — did such transfer of the hotel leasehold and…
2Cases cited4 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Merrill v. CommissionerUnited States Tax Court · 1963
- McWilliams v. CommissionerUnited States Board of Tax Appeals · 1929
- United States v. James H. Marshall and Thelma MarshallCourt of Appeals for the Ninth Circuit · 1966
3Cited by53 opinions
- Baird v. CommissionerUnited States Tax Court · 1977
- Clodfelter v. CommissionerUnited States Tax Court · 1971
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Derr v. CommissionerUnited States Tax Court · 1981
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