Legal Opinion

Sheraton Plaza Co. v. Commissioner

United States Tax Court

Decided January 18, 1963No. Docket No. 89380Published

Cancellation by petitioner's sole stockholder of debt previously created by unrelated tenant and assumed by petitioner's agreement with its stockholder when petitioner's property was acquired from original debtor, held, on facts, not to result in income taxable to petitioner.

1Opinion of the Court

Sheraton Plaza Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Sheraton Plaza Co. v. Commissioner

Docket No. 89380

United States Tax Court

39 T.C. 697; 1963 U.S. Tax Ct. LEXIS 206;

January 18, 1963, Filed

Decision will be entered for the petitioner.

Cancellation by petitioner's sole stockholder of debt previously created by unrelated tenant and assumed by petitioner's agreement with its stockholder when petitioner's property was acquired from original debtor, held, on facts, not to result in income taxable to petitioner.

Robert J. Richards, Jr., Esq., for the petitioner.

Albert R.…

2Cases cited19 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Commissioner v. JacobsonSupreme Court of the United States · 1949
  3. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  4. Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
  5. Magruder v. SuppleeSupreme Court of the United States · 1942

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