Palo Alto Town & Country Village, Inc. v. Commissioner Of Internal Revenue

565 F.2d 1388 78-1 USTC P 9200 PALO ALTO TOWN & COUNTRY VILLAGE, INC., Town & Country Construction Co., Inc., Ronald H. Williams and Ann G. Williams, Plaintiffs-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee. No. 74-2585. United States Court of Appeals, Ninth Circuit. Dec. 19, 1977. 1 Julian N. Stern (argued), of Heller, Ehrman, White & McAuliffe, San Francisco, Cal., for plaintiffs-appellants. 2 Dennis M. Donohue (argued), of Internal Revenue Service, Washington, D. C., for defendant-appellee. 3 Appeal from the United States Tax Court of the United States. 4 Before: CHAMBERS and GOODWIN, Circuit Judges, and SCHNACKE, District Judge. * SCHNACKE, District Judge: 5 This is an appeal by Palo Alto Town & Country Village, Inc. (hereinafter, "Palo Alto"); Ronald Williams, its president at the relevant times; and the latter's wife, Ann, from a Tax Court decision determining that Palo Alto owed $149,332.82 in income taxes for 1963-68 and that the Williamses owed $39,181.33 in income taxes for 1963-67. I. Cost Basis of Land 6 In 1959, the Williamses acquired two contiguous parcels of 9 and 42 acres, in several transactions. In the transaction here under…