Foster v. Comm'r
United States Tax Court
SUBSTANTIVE ISSUES Issues 1 and 3: REALLOCATIONS OF INCOME UNDER SEC. 482, I.R.C. 1954. T, J, D, and B (a father and three sons) were equal partners in FP, a general partnership. In 1958, FP began to investigate the development potential of Brewer's Island, a 2,600-acre undeveloped tract of land located about 12 miles south of San Francisco.
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SUBSTANTIVE ISSUES Issues 1 and 3: REALLOCATIONS OF INCOME UNDER SEC. 482, I.R.C. 1954. T, J, D, and B (a father and three sons) were equal partners in FP, a general partnership. In 1958, FP began to investigate the development potential of Brewer's Island, a 2,600-acre undeveloped tract of land located about 12 miles south of San Francisco. FP determined that the tract could be transformed into a city of 35,000. In December 1959, it acquired an option for the purchase of the land; in May 1960, it secured enabling legislation from the California legislature for a municipal improvement…
1Opinion of the Court
Richard H. Foster and Sara B. Foster, T. Jack Foster, Jr., and Patricia Foster, John R. Foster and Caroline Foster, and Estate of T. Jack Foster, Deceased, Gladys H. Foster, Executrix and Gladys H. Foster, Petitioners v. Commissioner of Internal Revenue, Respondent
Foster v. Comm'r
Docket No. 1717-78
United States Tax Court
80 T.C. 34; 1983 U.S. Tax Ct. LEXIS 127; 80 T.C. No. 3;
January 11, 1983, Filed
[EDITOR'S NOTE: PART 1 OF 2. THIS DOCUMENT HAS BEEN SPLIT INTO MULTIPLE PARTS ON LEXIS TO ACCOMMODATE ITS LARGE SIZE. EACH PART CONTAINS THE SAME LEXIS CITE.]
Decision will be entered under Rule 155.
SU…
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