Adelaide Park Land v. Commissioner
United States Board of Tax Appeals
The petitioner trust, with beneficiaries, voluntarily associated to acquire, subdivide, improve and sell a parcel of real estate for gainful purposes, is an association taxable as a corporation under the provisions of the Revenue Acts of 1921 and 1924.
1Opinion of the Court
*213OPINION.
Lansdon :
The petitioners’ first contention here is that it was. strictly a trust in the taxable years; that all the income realized from the sale of lots was distributable to the beneficiaries in proportion to their interests; and that such distributions having been made as contemplated by the trust instrument, it was not taxable in any of the years in question. The facts herein are similar to those found in G. F. Sloan et al., 24 B. T. A. 61, and, in our opinion, our decision there must control in this proceeding. Here, as there, a voluntary association was formed and financed to…
2Cases cited3 opinions
- Hecht v. MalleySupreme Court of the United States · 1924
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Dayton Bronze Bearing Co. v. GilliganCourt of Appeals for the Sixth Circuit · 1922
3Cited by7 opinions
- Jockey Club v. CommissionerUnited States Board of Tax Appeals · 1934
- Dolese & Shepherd Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Adelaide Park Land v. CommissionerUnited States Board of Tax Appeals · 1932
- Bloomfield Ranch v. CommissionerUnited States Tax Court · 1947
- Jockey Club v. CommissionerUnited States Board of Tax Appeals · 1934
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