Legal Opinion

Atlee v. Commissioner

United States Tax Court

Decided December 8, 1976No. Docket No. 4222-73Published

Petitioners and the Hansens each owned 50 percent of the stock of Hansen-Atlee, a corporation engaged primarily in the development and rental of commercial and residential properties. In 1969, petitioners and the Hansens devised a plan to divide the corporate business between them.

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Petitioners and the Hansens each owned 50 percent of the stock of Hansen-Atlee, a corporation engaged primarily in the development and rental of commercial and residential properties. In 1969, petitioners and the Hansens devised a plan to divide the corporate business between them. Pursuant to a plan of reorganization, dated Dec. 31, 1969, Atlee Enterprises, Inc., was formed and in return for all of its stock, Hansen-Atlee transferred to the new corporation: three pieces of undeveloped property, three notes, a leasehold interest, a car, a house trailer, and $ 500 cash. All three properties,…

1Opinion of the Court

Harry B. Atlee and Colleen Atlee, Petitioners v. Commissioner of Internal Revenue, Respondent

Atlee v. Commissioner

Docket No. 4222-73

United States Tax Court

67 T.C. 395; 1976 U.S. Tax Ct. LEXIS 12;

December 8, 1976, Filed

Decision will be entered under Rule 155.

Petitioners and the Hansens each owned 50 percent of the stock of Hansen-Atlee, a corporation engaged primarily in the development and rental of commercial and residential properties. In 1969, petitioners and the Hansens devised a plan to divide the corporate business between them. Pursuant to a plan of reorganization, dated Dec. 31, 1969,…

2Cases cited8 opinions

  1. Coady v. CommissionerUnited States Tax Court · 1960
  2. Portland Mfg. Co. v. CommissionerUnited States Tax Court · 1971
  3. United States v. W. W. Marett and Ruth MarettCourt of Appeals for the Fifth Circuit · 1963
  4. Atlee v. CommissionerUnited States Tax Court · 1976
  5. Burke v. CommissionerUnited States Tax Court · 1964

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