Sergio entered into a contract on March 25 to sell real estate for $1 million. The sale was subject to the condition that the property was rezoned from R-7 to CN-2. The adjusted basis of the property was $200,000. The purchaser placed $50,000 in escrow, which was refundable if the zoning was not accomplished by September 30.
Sergio continued working on the rezoning up until the day he died. He died on September 6. The rezoning was approved on September 17 and on September 19 the remainder of the purchase price, $950,000 was paid to his estate.
The fiduciary of Sergio’s estate is trying to work out whether the sale goes on the final return for Sergioor is included in the return for the estate and is seeking your advice as to when the sale occurred, why and the income tax and estate tax consequences. Did the sale occur before or after the death of Sergio?
A partial list of aids to help you with your research
§§691 and 1014
George W. Keck, 49 T.C. 313 (1968), rev’d 69-2 USTC ¶9626, 24 AFTR 2d 69-5554, 415 F.2d 531 (CA-6, 1969)
Trust Company of Georgia v. Ross, 68-1 USTC ¶9133, 21 AFTR 2d 311, 392 F.2d 694 (CA-5. 1967)
Prepare a tax research memo addressing the question that has been raised.
You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority Nor are IRS Publications.
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