Middle States Terminals, Inc. v. Commissioner
United States Tax Court
An Ohio truck terminal corporation with a single stockholder owned a terminal in Cincinnati and a partially constructed terminal in Chicago. It sold its Chicago terminal property to petitioner, an Illinois corporation created by the same single stockholder to borrow money and buy the Chicago terminal property. The evidence showed the formation of petitioner to acquire and finance the Chicago truck terminal was a prerequisite to the bank's granting the loan.
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An Ohio truck terminal corporation with a single stockholder owned a terminal in Cincinnati and a partially constructed terminal in Chicago. It sold its Chicago terminal property to petitioner, an Illinois corporation created by the same single stockholder to borrow money and buy the Chicago terminal property. The evidence showed the formation of petitioner to acquire and finance the Chicago truck terminal was a prerequisite to the bank's granting the loan. Held, petitioner sustained its burden of showing that securing the surtax exemption was not a major purpose of such transfer within…
1Opinion of the Court
Middle States Terminals, Inc. v. Commissioner.
Middle States Terminals, Inc. v. Commissioner
Docket No. 958-65.
United States Tax Court
T.C. Memo 1966-32; 1966 Tax Ct. Memo LEXIS 250; 25 T.C.M. (CCH) 203; T.C.M. (RIA) 66032;
February 17, 1966
An Ohio truck terminal corporation with a single stockholder owned a terminal in Cincinnati and a partially constructed terminal in Chicago. It sold its Chicago terminal property to petitioner, an Illinois corporation created by the same single stockholder to borrow money and buy the Chicago terminal property. The evidence showed the formation of petitioner to…
2Cases cited3 opinions
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- Hiawatha Home Builders, Inc. v. CommissionerUnited States Tax Court · 1961
- New England Foundry Corp. v. CommissionerUnited States Tax Court · 1965