Ebben v. Commissioner

783 F.2d 906 (1986)

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Ebben v. Commissioner

United States Court of Appeals for the Ninth Circuit
783 F.2d 906 (1986)

Facts

Leo Ebben (plaintiff) owned a piece of real estate with a fair market value of approximately $589,000. Ebben held the property subject to a nonrecourse loan secured by a deed of trust. Ebben owed approximately $544,000 on the loan. Ebben’s adjusted basis in the real estate was $548,000. Ebben made a charitable donation of the real estate to Pitzer College. The Internal Revenue Service (IRS) (defendant) determined that, for the purposes of § 1011(b) of the Internal Revenue Code (code), Ebben’s gift was a sale that resulted in taxable gain to Ebben. Ebben challenged the IRS’s characterization of the donation as a sale in the United States Tax Court. The Tax Court ruled in favor of the IRS, and Ebben appealed.

Rule of Law

Issue

Holding and Reasoning (Hall, J.)

Concurrence/Dissent (Beezer, J.)

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