T.C. Memo. 1995-601
UNITED STATES TAX COURT
TRACY P. STREBER, F.K.A. TRACY C. PARKER, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 345-92, 352-92, Filed December 20, 1995.
900-92.
Petitioner father (P1) entered into certain
earnest money contracts to purchase land that P1
intended to develop through a joint venture with third
parties who would provide the operating capital. P1
intended for his daughters (P2 and P3) to have an
interest in both the land and a future joint venture to
develop the land. To this end, P1 arranged to have an
agent act on behalf of P2 and P3 with respect to the
earnest money contracts and the joint venture. After
the joint venture began, the third parties “bought-out”
P1, P2, and P3 by giving them promissory notes. Years
later, subsequent to litigation in which P2 and P3
participated, the notes were paid.
1 Cases of the following petitioners are consolidated
herewith: Teresa P. Delony, F.K.A. Teresa R. Davis and
Stephen J. Davis, docket No. 352-92; Larry B. and Martha A.
Parker, docket No. 900-92.
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