Aldon Homes, Inc. v. Commissioner
United States Tax Court
Three individuals, hereinafter-called the management group, desired to subdivide and develop a tract of land. They organized Aldon Homes, Inc., and paid $ 4,500 for its stock. Other individuals, hereinafter called the investor group, advanced a net amount of $ 300,000 to Aldon with the understanding that they would receive 50 per cent of the profits from the enterprise.
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Three individuals, hereinafter-called the management group, desired to subdivide and develop a tract of land. They organized Aldon Homes, Inc., and paid $ 4,500 for its stock. Other individuals, hereinafter called the investor group, advanced a net amount of $ 300,000 to Aldon with the understanding that they would receive 50 per cent of the profits from the enterprise. Most members of the investor group received a portion of the stock held by the management group, but the management group retained a controlling interest in Aldon. Aldon utilized most of the $ 300,000 for the purpose of…
1Opinion of the Court
Bruce, Judge:
These proceedings involve the following deficiencies in income tax:
Docket No. Taxable period Petitioner Deficiency
60020 June 1,1951, to Dec. 31, 1951 Aldon Homes, Inc_ $102, 748. 90
60021 Jan. 1, 1951, to Dec. 26, 1951 Barca Corporation_ 4, 582. 54
The issues relating to Aldon Homes, Inc., are: (1) Is respondent correct in disregarding the existence of Barca Corporation and of 15 other corporate entities, and in imputing the combined net income of these 16 corporations to Aldon Homes, Inc., pursuant to section 22(a),1 or (2) in the alternative, is respondent correct in attributing…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
13 more not listed; retrieve them via the Exa API.
3Cited by76 opinions
- Bolger v. CommissionerUnited States Tax Court · 1973
- Shaw Construction Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- American Sav. Bank v. CommissionerUnited States Tax Court · 1971
- Bush Hog Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- Shaw Constr. Co. v. CommissionerUnited States Tax Court · 1961
71 more not listed; retrieve them via the Exa API.