Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 1

                                 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.           

                    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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