Cary v. Commissioner
United States Tax Court
Petitioners' wholly-owned corporation, Pica, was engaged in the real estate development business. Pica contracted to purchase two large tracts of land to subdivide and sell. At closing time Pica did not have sufficient cash to commit to the settlement requirements and carrying charges until these tracts could be developed.
Read the full summary
Petitioners' wholly-owned corporation, Pica, was engaged in the real estate development business. Pica contracted to purchase two large tracts of land to subdivide and sell. At closing time Pica did not have sufficient cash to commit to the settlement requirements and carrying charges until these tracts could be developed. Pica sold the tracts to petitioners at its cost who in turn sold the tracts to syndicates in which petitioners owned 50-percent interests and unrelated third parties, who put up the necessary cash, owned the other 50-percent interests. The participants in the syndicates…
1Opinion of the Court
THOMAS A. CARY and THOMAS A. CARY AND WARD H. OEHMANN, EXECUTORS U/W ANNA MAY CARY, DECEASED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cary v. Commissioner
Docket No. 6336-69.
United States Tax Court
T.C. Memo 1973-197; 1973 Tax Ct. Memo LEXIS 87; 32 T.C.M. (CCH) 913; T.C.M. (RIA) 73197;
September 10, 1973, Filed
Petitioners' wholly-owned corporation, Pica, was engaged in the real estate development business. Pica contracted to purchase two large tracts of land to subdivide and sell. At closing time Pica did not have sufficient cash to commit to the settlement requirements and…
2Cases cited19 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Burnet v. ClarkSupreme Court of the United States · 1932
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
14 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Bramblett v. CommissionerUnited States Tax Court · 1990