Legal Opinion

Falk v. Commissioner

United States Tax Court

Decided May 18, 1961No. Docket Nos. 54477, 54478, 54479, 54480Published

During 1949 petitioners transferred all of their stock in Warwick Center Corporation to Warwick Gardens #2, Inc., in exchange for cash and negotiable interest-bearing promissory notes due in 1 year. At the time of the exchange petitioners owned all the stock in both corporations in disproportionate amounts. The notes were paid in 1950 with interest.

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During 1949 petitioners transferred all of their stock in Warwick Center Corporation to Warwick Gardens #2, Inc., in exchange for cash and negotiable interest-bearing promissory notes due in 1 year. At the time of the exchange petitioners owned all the stock in both corporations in disproportionate amounts. The notes were paid in 1950 with interest. After the transfer, Warwick Gardens #2, Inc., liquidated Warwick Center Corporation and on a parcel of land received in liquidation it constructed in 1949 apartment houses financed under section 608 of the National Housing Act. Petitioners Brout…

1Opinion of the Court

Emanuel E. Falk and Jean B. Falk, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Falk v. Commissioner

Docket Nos. 54477, 54478, 54479, 54480

United States Tax Court

36 T.C. 292; 1961 U.S. Tax Ct. LEXIS 148;

May 18, 1961, Filed

Decisions will be entered under Rule 50.

During 1949 petitioners transferred all of their stock in Warwick Center Corporation to Warwick Gardens #2, Inc., in exchange for cash and negotiable interest-bearing promissory notes due in 1 year. At the time of the exchange petitioners owned all the stock in both corporations in disproportionate amounts. The…

2Cases cited5 opinions

  1. Sidney v. CommissionerUnited States Tax Court · 1958
  2. Wolfson v. ReineckeCourt of Appeals for the Seventh Circuit · 1934
  3. Arthur P. And Teresa Pomponio, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
  4. Pomponio v. CommissionerUnited States Tax Court · 1960
  5. Falk v. CommissionerUnited States Tax Court · 1961

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