44 West 3rd Street Corp. v. Commissioner
United States Tax Court
On August 5, 1955, pursuant to the provisions of the New York City Administrative Code, the city was vested with title and the right to possession under an order of condemnation of certain real property of petitioner corporation. On January 28, 1956, the corporation adopted a plan of liquidation and within 12 months dissolved and distributed its assets to its three stockholders, leaving the corporation insolvent.
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On August 5, 1955, pursuant to the provisions of the New York City Administrative Code, the city was vested with title and the right to possession under an order of condemnation of certain real property of petitioner corporation. On January 28, 1956, the corporation adopted a plan of liquidation and within 12 months dissolved and distributed its assets to its three stockholders, leaving the corporation insolvent. On September 25, 1956, the final decree fixing the amount of the condemnation award was entered and on November 5, 1956, the amount was paid to the corporation by the city of New…
1Opinion of the Court
44 West 3rd Street Corporation, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
44 West 3rd Street Corp. v. Commissioner
Docket Nos. 86024, 86025, 86164, 86165
United States Tax Court
39 T.C. 809; 1963 U.S. Tax Ct. LEXIS 193;
February 14, 1963, Filed
Decisions will be entered for the respondent in all four dockets.
On August 5, 1955, pursuant to the provisions of the New York City Administrative Code, the city was vested with title and the right to possession under an order of condemnation of certain real property of petitioner corporation. On January 28, 1956, the corporation…
2Cases cited13 opinions
- Helvering v. HammelSupreme Court of the United States · 1941
- Miles v. Safe Deposit & Trust Co. of BaltimoreSupreme Court of the United States · 1922
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
- Wood Harmon Corporation v. United StatesCourt of Appeals for the Second Circuit · 1963
- Hawaiian Gas Products v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1942
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