Haley Bros. Constr. Corp. v. Commissioner
United States Tax Court
On June 18, 1977, petitioner HBC, then a subchapter S corporation, acquired all the stock of an existing corporation (M) that was actively engaged in the business of developing and selling residential real estate lots from a subdivision it owned. Because M was indebted to HBC and was experiencing financial difficulties, HBC decided to acquire M's stock and to complete the real estate development itself.
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On June 18, 1977, petitioner HBC, then a subchapter S corporation, acquired all the stock of an existing corporation (M) that was actively engaged in the business of developing and selling residential real estate lots from a subdivision it owned. Because M was indebted to HBC and was experiencing financial difficulties, HBC decided to acquire M's stock and to complete the real estate development itself. HBC proceeded to clear up M's outstanding debts and, in many respects, operated M as if it were a division of itself. HBC, formally dissolved M on May 10, 1979. Held: HBC's subchapter S…
1Opinion of the Court
Haley Brothers Construction Corp., Estate of John W. Haley, John W. Haley, Jr., and Joseph A. Haley, Executors, and Mary A. Haley, Estate of Francis J. Haley, Bonnie J. Haley, Executrix, and Bonnie J. Haley, Petitioners v. Commissioner of Internal Revenue, Respondent
Haley Bros. Constr. Corp. v. Commissioner
Docket No. 8585-81
United States Tax Court
87 T.C. 498; 1986 U.S. Tax Ct. LEXIS 63; 87 T.C. No. 26;
August 18, 1986, Filed
Decision will be entered for the respondent. 22
On June 18, 1977, petitioner HBC, then a subchapter S corporation, acquired all the stock of an existing corporation (M) that…
2Cases cited17 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Swanson v. CommissionerSupreme Court of the United States · 1935
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