Chaney & Hope, Inc. v. Commissioner
United States Tax Court
Alps Corp. was one of a group of corporations involved in the construction business. The stock in all of these corporations was owned by the same individuals and the percentage of the stock ownership which each of these individuals had in one corporation was approximately the same percentage that he had in any of the other corporations.
Read the full summary
Alps Corp. was one of a group of corporations involved in the construction business. The stock in all of these corporations was owned by the same individuals and the percentage of the stock ownership which each of these individuals had in one corporation was approximately the same percentage that he had in any of the other corporations. A majority interest in each of the corporations was held by one individual, H. H operated the corporations in the group in tandem with one another. Alps Corp. throughout its entire existence, never paid a dividend to its shareholders. During the fiscal years…
1Opinion of the Court
Scott, Judge:
Respondent determined liabilities of petitioner Chaney & Hope, Inc., as transferee based upon deficiencies in income tax of its transferor, Alps Corp., for its fiscal years ended September 30,1973, September 30,1974, and the period October 1, 1974, through July 31, 1975, in the respective amounts of $4,919.20, $5,138.38, and $6,876.93.
The issue for decision is whether Alps Corp. was availed of during each of its fiscal years ended September 30, 1973 and 1974, and the period October 1, 1974, through July 31, 1975, for the purpose of avoiding Federal income tax with respect to its…
2Cases cited16 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- United States v. Donruss Co.Supreme Court of the United States · 1969
- The Smoot Sand & Gravel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Faber Cement Block Co. v. CommissionerUnited States Tax Court · 1968
- Ivan Allen Co. v. United StatesSupreme Court of the United States · 1975
11 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Frank v. International Canadian Corp.Court of Appeals for the Ninth Circuit · 1962
- EMI Corp. v. CommissionerUnited States Tax Court · 1985
- Feilen Meat Co. v. CommissionerUnited States Tax Court · 1984
- Petrozello Co. v. CommissionerUnited States Tax Court · 1983
- Rhoades Oil Co. v. CommissionerUnited States Tax Court · 1985
3 more not listed; retrieve them via the Exa API.