Pittsburgh Realty Inv. Trust v. Commissioner
United States Tax Court
College Housing, Inc. (CHI), owned and operated dormitories at Indiana University, Indiana, Pa. Petitioner negotiated to buy those assets and operate the dormitories as an investment for the trust. The three stockholders of CHI would not agree to having CHI sell its assets but did enter into an agreement to sell their stock to petitioner.
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College Housing, Inc. (CHI), owned and operated dormitories at Indiana University, Indiana, Pa. Petitioner negotiated to buy those assets and operate the dormitories as an investment for the trust. The three stockholders of CHI would not agree to having CHI sell its assets but did enter into an agreement to sell their stock to petitioner. The closing was supposed to take place on Sept. 30, 1968, but did not actually take place until Oct. 4, 1968. Thereafter petitioner liquidated CHI and received its assets in liquidation. The liquidation of CHI triggered additional taxes for CHI resulting…
1Opinion of the Court
Pittsburgh Realty Investment Trust, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent
Pittsburgh Realty Inv. Trust v. Commissioner
Docket Nos. 1786-73, 9887-74
United States Tax Court
67 T.C. 260; 1976 U.S. Tax Ct. LEXIS 21;
November 22, 1976, Filed
Decision will be entered for the respondent in docket No. 9887-74.
Docket No. 1786-73 will be dismissed for lack of jurisdiction.
College Housing, Inc. (CHI), owned and operated dormitories at Indiana University, Indiana, Pa. Petitioner negotiated to buy those assets and operate the dormitories as an investment for the trust. The…
2Cases cited34 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
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