Tax Court Memorandum Decisions

acquired acres additions to tax AFTR 2d agreed agreement amount Aniline April April 30 assets bad debt bank basis capital gain cash Cherry Hill Cite claimed Commissioner Company contract corporation cost Court decedent December December 31 deduction deficiency determined disallowed Docket Eghigian evidence Fairmount Park February 28 filed FINDINGS OF FACT fiscal year ended Frank and McNatt gross income held hereinafter income tax returns interest Internal Revenue Code issue January January 15 land lease liability loans loss lots MEMORANDUM FINDINGS ment operation option ordinary income P-H Fed P-H Memo TC paid parties partners partnership payments percent period peti petitioner petitioner's poration prior profit purchase real estate receipts received record Reference rental reported respect respondent respondent's shares sold spondent stipulated stockholders supra tax returns taxpayer tion tioner trade or business transaction trust wife