Legal Opinion

Ambassador Apartments, Inc. v. Commissioner of Internal Revenue, Louis Litoff and Rose Litoff v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided January 9, 1969No. 227-229, Dockets 32699-32701PublishedCited by 41 opinions

1Per curiam

In September 1958, Louis and Rose Litoff purchased an apartment building for $642,669.61. They took the property subject to two mortgages totaling $319,-095.97, gave a third mortgage for $125,-000 and paid $198,573.64 in cash. A year later the Litoffs organized Ambassador Apartments, Inc., to which they transferred the apartment building in exchange for Ambassador stock and a note in the amount of $193,511.56 secured by a fourth mortgage. After the transfer Ambassador listed assets of $648,187.27, liabilities of $643,187.27 and stockholders equity of only $5,000.

The fourth mortgage note…

2Cases cited5 opinions

  1. Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
  2. Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
  3. Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
  4. J. S. Biritz Construction Co. v. Commissioner of Internal Revenue, Joseph S. Biritz and Dorothy Biritz v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1967
  5. The Motel Company v. The Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965

3Cited by41 opinions

  1. Siegel v. CommissionerUnited States Tax Court · 1982
  2. Falsetti v. CommissionerUnited States Tax Court · 1985
  3. Narver v. CommissionerUnited States Tax Court · 1980
  4. Estate of Spruill v. CommissionerUnited States Tax Court · 1987
  5. W. Larry Harlan and Mary Jane Harlan v. United StatesCourt of Appeals for the Fifth Circuit · 1969

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