Householder v. Commissioner
United States Tax Court
In year one, P1 formed P2, a C corporation, and was its sole shareholder. In year one, P2 built an apartment complex and rented the complex for four years. In year five, P2 sold the apartment complex, and P1 reported the gain from the sale, under the installment method, in years five and six on his return. Held: P2 did not execute a deed conveying ownership in the apartment complex to P1 in year one, so P2 was the owner of the complex.
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In year one, P1 formed P2, a C corporation, and was its sole shareholder. In year one, P2 built an apartment complex and rented the complex for four years. In year five, P2 sold the apartment complex, and P1 reported the gain from the sale, under the installment method, in years five and six on his return. Held: P2 did not execute a deed conveying ownership in the apartment complex to P1 in year one, so P2 was the owner of the complex. Held further: P2 will not be disregarded as a taxable entity because it had a valid business purpose and conducted business activities. Held further: P2 was…
1Opinion of the Court
JANE MELTON HOUSEHOLDER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Householder v. Commissioner
Docket Nos. 35749-85; 35800-85; 35801-85
United States Tax Court
T.C. Memo 1989-561; 1989 Tax Ct. Memo LEXIS 559; 58 T.C.M. (CCH) 382; T.C.M. (RIA) 89561;
October 11, 1989
In year one, P1 formed P2, a C corporation, and was its sole shareholder. In year one, P2 built an apartment complex and rented the complex for four years. In year five, P2 sold the apartment complex, and P1 reported the gain from the sale, under the installment method, in years five and six on his return.
Held…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Griffiths v. CommissionerSupreme Court of the United States · 1939
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