Legal Opinion

Jarret v. Commissioner

United States Tax Court

Decided November 9, 1993No. Docket No. 4576-92Unpublished

P, an attorney who also ran a real estate development business with B, purchased a parcel of land with B in 1985. One portion fronted on a public road; P and B divided this portion into 21 lots, which they sold. The other portion, the Backland, was unmarketable without further developmental work.

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P, an attorney who also ran a real estate development business with B, purchased a parcel of land with B in 1985. One portion fronted on a public road; P and B divided this portion into 21 lots, which they sold. The other portion, the Backland, was unmarketable without further developmental work. P and B performed such work over a 1-1/2 year period, and attended planning board meetings in order to obtain approval for a subdivision so that they could sell the Backland to a developer. They sold the Backland to a developer 1 month after they obtained such approval. Held: The Backland is not a…

1Opinion of the Court

ARAM P. JARRET, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Jarret v. Commissioner

Docket No. 4576-92

United States Tax Court

T.C. Memo 1993-516; 1993 Tax Ct. Memo LEXIS 527; 66 T.C.M. (CCH) 1224;

November 9, 1993, Filed

Decision will be entered under Rule 155.

P, an attorney who also ran a real estate development business with B, purchased a parcel of land with B in 1985. One portion fronted on a public road; P and B divided this portion into 21 lots, which they sold. The other portion, the Backland, was unmarketable without further developmental work. P and B performed such work…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Neely v. CommissionerUnited States Tax Court · 1985
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Pallottini v. CommissionerUnited States Tax Court · 1988
  5. Bauschard v. CommissionerUnited States Tax Court · 1959

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