What is the test for determining the value of a property for tax purposes?
MultiRegion, United States of America
The following excerpt is from Bryant v. C.I.R., 790 F.2d 1463 (9th Cir. 1986):
"does not apply where a transaction is not conducted at arm's-length by two economically self-interested parties or where a transaction is based upon 'peculiar circumstances' which influence the purchaser to agree to a price in excess of the property's fair market value." ... In such cases, the basis of property for tax purposes may be limited to fair market value.
Lemmen, 77 T.C. at 1347 (citations omitted) (quoting Bixby v. Commissioner, 58 T.C. 757, 776 (1972)).
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