Thomas v. Commissioner
United States Tax Court
A received an option to purchase some undeveloped land which was zoned for agricultural use. Together with B and C, A formed a corporation, M, to which A's option was transferred. A owned 100 percent of M's issued and outstanding stock while B and C held options for one-third of M's stock. After M succeeded in having its land rezoned for residential use, M adopted a plan of liquidation and sold the land.
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A received an option to purchase some undeveloped land which was zoned for agricultural use. Together with B and C, A formed a corporation, M, to which A's option was transferred. A owned 100 percent of M's issued and outstanding stock while B and C held options for one-third of M's stock. After M succeeded in having its land rezoned for residential use, M adopted a plan of liquidation and sold the land. No other activities were conducted with regard to the land; M made no physical improvements to the land. Held, M was not a collapsible corporation as defined and thus is not required to…
1Opinion of the Court
CALVIN A. THOMAS, TRANSFEREE OF METRO "400" INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Thomas v. Commissioner
Docket Nos. 11998-77, 11999-77, 12000-77, 157-78, 831-78, 1140-78.
United States Tax Court
T.C. Memo 1981-387; 1981 Tax Ct. Memo LEXIS 362; 42 T.C.M. (CCH) 496; T.C.M. (RIA) 81387;
July 28, 1981.
A received an option to purchase some undeveloped land which was zoned for agricultural use. Together with B and C, A formed a corporation, M, to which A's option was transferred. A owned 100 percent of M's issued and outstanding stock while B and C held options for…
2Cases cited39 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Malat v. RiddellSupreme Court of the United States · 1966
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
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