Legal Opinion

Estate of Krafft v. Commissioner

United States Tax Court

Decided October 31, 1961No. Docket No. 76355Unpublished

The petitioner operated a restaurant and retail merchandise business on premises leased from a corporation which she controlled. She made certain improvements upon the leased premises.

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The petitioner operated a restaurant and retail merchandise business on premises leased from a corporation which she controlled. She made certain improvements upon the leased premises. After four years of operations resulting in substantial losses, she sold the business, including the leasehold improvements and other business property, to another corporation, 85 percent of the stock of which she owned, the consideration being the assumption by such corporation of indebtedness of the petitioner arising out of the business and consisting principally of indebtedness owing to the lessor…

1Opinion of the Court

Estate of Walter A. Krafft, Deceased, Julia C. Krafft and The Continental Illinois National Bank and Trust Company of Chicago, Illinois, Executors, and Julia C. Krafft, individually v. Commissioner.

Estate of Krafft v. Commissioner

Docket No. 76355.

United States Tax Court

T.C. Memo 1961-305; 1961 Tax Ct. Memo LEXIS 48; 20 T.C.M. (CCH) 1571; T.C.M. (RIA) 61305;

October 31, 1961

The petitioner operated a restaurant and retail merchandise business on premises leased from a corporation which she controlled. She made certain improvements upon the leased premises. After four years of operations…

2Cases cited13 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
  3. Horton v. CommissionerUnited States Tax Court · 1949
  4. Raymond Lee Mills v. United StatesCourt of Appeals for the Fourth Circuit · 1960
  5. C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949

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