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PALO ALTO TOWN & COUNTRY VILLAGE, INC. v. C. I. R.

No. 74-2585.

565 F.2d 1388 (1977)

PALO ALTO TOWN & COUNTRY VILLAGE, INC., Town & Country Construction Co., Inc., Ronald H. Williams and Ann G. Williams, Plaintiffs-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

December 19, 1977.

Attorney(s) appearing for the Case

Julian N. Stern (argued), of Heller, Ehrman, White & McAuliffe, San Francisco, Cal., for plaintiffs-appellants.

Dennis M. Donohue (argued), of Internal Revenue Service, Washington, D. C., for defendant-appellee.

Before: CHAMBERS and GOODWIN, Circuit Judges, and SCHNACKE, District Judge.

SCHNACKE, District Judge:

This is an appeal by Palo Alto Town & Country Village, Inc. (hereinafter, "Palo Alto"); Ronald Williams, its president at the relevant times; and the latter's wife, Ann, from a Tax Court decision determining that Palo Alto owed $149,332.82 in income taxes for 1963-68 and that the Williamses owed $39,181.33 in income taxes for 1963-67.

I. Cost Basis of Land

In 1959, the Williamses acquired two contiguous parcels...

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