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ALLAN v. C.I.R.

No. 86-2268.

856 F.2d 1169 (1988)

James A. ALLAN and Eileen Allan; Dennis M. Evavold and Joanne L. Evavold; Lowell Gordon; Donald J. Hamm and Beverly J. Hamm; William D.C. Mattison and Barbara A. Mattison; Bruce M. Nelson and Doris A. Nelson; Robert Osterbauer; Daniel R. Vaughan and Roberta E. Vaughan, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided September 16, 1988.

Attorney(s) appearing for the Case

Bruce R. Ellisen, Washington, D.C., for appellant.

Steven L. Ross, Minneapolis, Minn., for appellees.

Before LAY, Chief Judge, and HEANEY and MAGILL, Circuit Judges.

MAGILL, Circuit Judge.

In this case, we review that part of a decision of the United States Tax Court1 holding that the entire amount of a nonrecourse obligation, including the original mortgage principal and advances made by the mortgagee for interest payments, was properly included in the "amount realized" upon the transfer of the property. For the following reasons, we affirm.

I....

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