Short v. Commissioner
United States Tax Court
Petitioners' contention that at least 30 percent of the gain recognized on the redemption of their stock in collapsible corporations was attributable other than to the property manufactured, constructed, produced, or purchased is rejected. Held, gain on redemption of petitioners' stock was properly considered as gain from the sale or exchange of property which is not a capital asset.
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in the income tax of the petitioners for 1950 as follows:
Petitioner Deficiency
Frank B. Short and Katherine F. Short_$25, 444.22
Richard L. Coleman and Betty B. Coleman_ 23, 318. 08
The sole issue to be decided is whether Edgewood Knoll Apartments, Inc., and Coleman Apartments, Inc., are collapsible corporations within the purview of section 117 (m) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Petitioners Richard L. Coleman (hereinafter referred to as Coleman) and Betty B. Coleman are husband and wife residing at Asheville, North Carolina.…
2Cases cited14 opinions
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- R. A. Bryan and Ruby M. Bryan, C. B. McNairy and Rowena A. McNairy W. H. Weaver and Edith H. Weaver v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Sidney v. CommissionerUnited States Tax Court · 1958
9 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Frank B. Short and Katherine F. Short, and Richard L. Coleman and Betty B. Coleman v. Commission of Interenal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Braude v. CommissionerUnited States Tax Court · 1961
- Braude v. CommissionerUnited States Tax Court · 1961
- Short v. CommissionerUnited States Tax Court · 1961