Legal Opinion

Curry v. Commissioner

United States Tax Court

Decided February 18, 1965No. Docket Nos. 2655-62, 2656-62, 2657-62, 2741-62Published

Four adult members of a family transferred income-producing real property to a corporation controlled partly by two of the transferors and partly by a related third person. Held, on the facts, the transaction constituted a bona fide sale; two mortgage notes executed by the corporation represented bona fide indebtedness; the transaction is not governed by section 351, I.R.C. 1954.

1Opinion of the Court

Charles E. and Ruth D. Curry (now Ruth D. Morgan), et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Curry v. Commissioner

Docket Nos. 2655-62, 2656-62, 2657-62, 2741-62

United States Tax Court

43 T.C. 667; 1965 U.S. Tax Ct. LEXIS 125;

February 18, 1965, Filed February 18, 1965, Filed

Decision will be entered for the petitioner in docket No. 2656-62.

Decisions will be entered under Rule 50 in docket Nos. 2655-62, 2657-62, and 2741-62.

Four adult members of a family transferred income-producing real property to a corporation controlled partly by two of the transferors and partly…

2Cases cited22 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
  4. Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
  5. Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955

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