Hartman v. Commissioner
United States Tax Court
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
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- 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
- Burge v. CommissionerUnited States Tax Court · 1957
- C. D. Spangler and Veva C. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
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