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