Broadway-Brompton Bldgs. Liquidation Trust v. Commissioner
United States Board of Tax Appeals
The petitioner was created under an agreement by the bondholders under two defaulted mortgages for the purpose of acquiring and selling the assets covered by the mortgages, distributing the proceeds to the bondholders and liquidating the trust as soon as practicable. Such assets consisted of two apartment houses, store rooms and a public garage which are being operated by the trust pending the sale of the property.
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The petitioner was created under an agreement by the bondholders under two defaulted mortgages for the purpose of acquiring and selling the assets covered by the mortgages, distributing the proceeds to the bondholders and liquidating the trust as soon as practicable. Such assets consisted of two apartment houses, store rooms and a public garage which are being operated by the trust pending the sale of the property. Held, that the petitioner was a liquidating trust and not an association taxable as a corporation.
1Opinion of the Court
BROADWAY-BROMPTON BUILDINGS LIQUIDATION TRUST, AMERICAN NATIONAL BANK AND TRUST COMPANY OF CHICAGO, TRUSTEE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Broadway-Brompton Bldgs. Liquidation Trust v. Commissioner
Docket No. 82818.
United States Board of Tax Appeals
34 B.T.A. 1089; 1936 BTA LEXIS 600;
October 13, 1936, Promulgated
The petitioner was created under an agreement by the bondholders under two defaulted mortgages for the purpose of acquiring and selling the assets covered by the mortgages, distributing the proceeds to the bondholders and liquidating the trust as soon as…
2Cases cited1 opinion
- Broadway-Brompton Bldgs. Liquidation Trust v. CommissionerUnited States Board of Tax Appeals · 1936