MAJOR REALTY CORPORATION & SUBSIDIARIES v. COMMISSIONER

Docket No. 4871-75.

42 T.C.M. 373 (1981)

T.C. Memo. 1981-361

Major Realty Corporation & Subsidiaries v. Commissioner.

United States Tax Court.

Filed July 13, 1981.


Attorney(s) appearing for the Case

James A. Urban and Bradley J. Davis, 1601 C.N.A. Tower, Orlando, Fla., for petitioners. Thomas K. Purcell, for respondent.


Memorandum Opinion

IRWIN, Judge:

Respondent determined a deficiency of $141,953 in petitioners' consolidated Federal income tax for the taxable year ending May 31, 1972.

Due to concessions by both sides, the only issues presented for our consideration are: (1) Whether the transactions herein described between petitioners and the Edward J. DeBartolo Corporation for the transfer of 175 acres of land constituted a completed sale or was, in substance...

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