Pittsburgh Realty Inv. Trust v. Commissioner
United States Tax Court
College Housing, Inc. (CHI), owned and operated dormitories at Indiana University, Indiana, Pa. Petitioner negotiated to buy those assets and operate the dormitories as an investment for the trust. The three stockholders of CHI would not agree to having CHI sell its assets but did enter into an agreement to sell their stock to petitioner.
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College Housing, Inc. (CHI), owned and operated dormitories at Indiana University, Indiana, Pa. Petitioner negotiated to buy those assets and operate the dormitories as an investment for the trust. The three stockholders of CHI would not agree to having CHI sell its assets but did enter into an agreement to sell their stock to petitioner. The closing was supposed to take place on Sept. 30, 1968, but did not actually take place until Oct. 4, 1968. Thereafter petitioner liquidated CHI and received its assets in liquidation. The liquidation of CHI triggered additional taxes for CHI resulting…
1Opinion of the Court
Drennen, Judge:
In docket No. 1786-73, respondent determined that petitioner was liable as a transferee for a deficiency of $38,189.48 in income tax due from College Housing, Inc., for the short taxable period January 1, 1968, through September 30, 1968. In docket No. 9887-74, respondent determined that petitioner was liable as a transferee for the same substantive deficiency of $38,189.48 due from College Housing, Inc., as in docket No. 1786-73 but for the taxable year beginning January 1, 1968, and ending December 31, 1968.1 The primary issue raised in these consolidated cases is the…
2Cases cited33 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
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