Day v. Commissioner
United States Tax Court
A corporation organized for the development of real estate subdivisions and the construction and sale of houses was liquidated in 1963, after it had realized 100 percent, 93 percent, and 56 percent, respectively, of the taxable income to be derived from its three projects.
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A corporation organized for the development of real estate subdivisions and the construction and sale of houses was liquidated in 1963, after it had realized 100 percent, 93 percent, and 56 percent, respectively, of the taxable income to be derived from its three projects. Held, the corporation was not a collapsible one within the meaning of sec. 341, I.R.C. 1954, because, at the time it was liquidated, it had already realized a substantial part of the taxable income to be derived from its real estate subdivision property.
1Opinion of the Court
George W. Day and Muriel E. Day, Petitioners v. Commissioner of Internal Revenue, Respondent
Day v. Commissioner
Docket No. 5684-67
United States Tax Court
55 T.C. 257; 1970 U.S. Tax Ct. LEXIS 35;
November 2, 1970, Filed
Decision will be entered for the petitioners.
A corporation organized for the development of real estate subdivisions and the construction and sale of houses was liquidated in 1963, after it had realized 100 percent, 93 percent, and 56 percent, respectively, of the taxable income to be derived from its three projects. Held, the corporation was not a collapsible one within the…
2Cases cited9 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
- Commissioner of Internal Revenue v. James B. Kelley and Lena S. Kelley, and John Waltman and Doris WaltmanCourt of Appeals for the Fifth Circuit · 1961
- Kelley v. CommissionerUnited States Tax Court · 1959
- Levenson v. United StatesDistrict Court, N.D. Alabama · 1957
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