SANFORD HOMES, INC. v. COMMISSIONER

Docket No. 8277-83.

52 T.C.M. 310 (1986)

T.C. Memo. 1986-404

Sanford Homes, Inc. v. Commissioner.

United States Tax Court.

Filed August 27, 1986.


Attorney(s) appearing for the Case

Melvin A. Coffee and Michael T. McDonnell, 2121 South Oneida Street, Denver, Colo., for the petitioner. Mark H. Howard, for the respondent.


Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax of $580,713.00 for 1979, or alternatively, $294,736.00 for 1980. There are two issues: (1) whether property distributed by a partnership to petitioner's subsidiary1 was held by the partnership for investment or for sale customers; and (2) whether section 7512 applies to distributions...

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