Legal Opinion

Hartman v. Commissioner

United States Tax Court

Decided September 22, 1960No. Docket No. 65826Published

Two wholly owned corporations were each availed of with a view to distributions of the excess proceeds of FHA-insured mortgages prior to corporate realization of a substantial part of the net income to be derived from the properties so mortgaged, and the fact that said distributions to sole common stockholder were unaccompanied by surrenders of any stock does not operate to take them out of the operation of section 117(m), I.R.C. 1939.

1Opinion of the Court

Jesse Hartman and Dorothy S. Hartman, Petitioners, v. Commissioner of Internal Revenue, Respondent

Hartman v. Commissioner

Docket No. 65826

United States Tax Court

34 T.C. 1085; 1960 U.S. Tax Ct. LEXIS 70;

September 22, 1960, Filed

Decision will be entered for the respondent.

Two wholly owned corporations were each availed of with a view to distributions of the excess proceeds of FHA-insured mortgages prior to corporate realization of a substantial part of the net income to be derived from the properties so mortgaged, and the fact that said distributions to sole common stockholder were unaccompanied…

2Cases cited11 opinions

  1. Helvering v. New York Trust Co.Supreme Court of the United States · 1934
  2. Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
  3. Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
  4. Burge v. CommissionerUnited States Tax Court · 1957
  5. C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960

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