Pleasant Summit Land Corp. v. Commissioner

863 F.2d 263, cert. denied sub nom. Commissioner v. Prussin, 493 U.S. 901 (1989)

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Pleasant Summit Land Corp. v. Commissioner

United States Court of Appeals for the Third Circuit
863 F.2d 263, cert. denied sub nom. Commissioner v. Prussin, 493 U.S. 901 (1989)

Facts

Pleasant Summit Land Corporation (Pleasant) (plaintiff) purchased property by giving the seller a nonrecourse mortgage in an amount greater than the fair market value of the property. Pleasant took depreciation deductions on the property for the full value of the loan. The commissioner of internal revenue (commissioner) (defendant) disallowed the deductions that were in excess of the property’s fair market value. Pleasant petitioned the tax court for a redetermination. The tax court ruled for the commissioner, and Pleasant appealed.

Rule of Law

Issue

Holding and Reasoning (Greenberg, J.)

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