Long v. Commissioner

772 F.3d 670 (2014)

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Long v. Commissioner

United States Court of Appeals for the Eleventh Circuit
772 F.3d 670 (2014)

  • Written by Heather Whittemore, JD

Facts

Philip Long (plaintiff) had an option to purchase land owned by the Las Olas Riverside Hotel (LORH). LORH unilaterally terminated its contract with Long, and Long sued LORH. Long then sold his position as plaintiff in the lawsuit for $5.75 million. Long reported the $5.75 million on his income-tax return as a long-term capital gain under § 1221 of the Internal Revenue Code. The Commissioner of Internal Revenue (the Commissioner) (defendant) determined that Long’s proceeds from assigning his claim against LORH was a lump-sum substitute for ordinary income that Long would have received by developing the land he had intended to purchase. The United States Tax Court affirmed the Commissioner’s determination. In reaching its decision, the tax court treated the land that Long had intended to purchase as the property subject to the capital-gains analysis. Long appealed.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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