112 T.C. No. 15
UNITED STATES TAX COURT
WILLIAM T. GLADDEN AND NICOLE L. GLADDEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16932-97. Filed April 15, 1999.
On cross-motions for partial summary judgment,
held, partnership water rights constitute capital
assets. Held, further, no portion of partnership's tax
basis in land the partnership acquired in 1976 is to be
allocated to the water rights the partnership acquired
in 1983 and relinquished in 1992.
William Louis Raby, Burgess J. William Raby, and
James J. Rossie, Jr., for petitioners.
Katherine Holmes Ankeny, for respondent.
OPINION
SWIFT, Judge: This matter is before us on the parties'
motions and cross-motions for partial summary judgment.
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