Legal Opinion

Huey & Philip Hardware Co. v. Commissioner

United States Board of Tax Appeals

Decided October 24, 1939No. Docket No. 92801Published

Petitioner and a realty corporation, owning and holding real estate which petitioner rented and used in its business, had substantially the same stockholders and officers, though there were some differences and the two corporations were operated as separate entities. , petitioner had loaned the realty company money in prior years and in 1934 took its demand promissory note secured by a second mortgage in settlement of its indebtedness.

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Petitioner and a realty corporation, owning and holding real estate which petitioner rented and used in its business, had substantially the same stockholders and officers, though there were some differences and the two corporations were operated as separate entities. , petitioner had loaned the realty company money in prior years and in 1934 took its demand promissory note secured by a second mortgage in settlement of its indebtedness. In November 1935, the realty company being in default, petitioner instituted foreclosure proceedings and petitioner purchased the property at foreclosure sale…

1Opinion of the Court

HUEY & PHILP HARDWARE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Huey & Philip Hardware Co. v. Commissioner

Docket No. 92801.

United States Board of Tax Appeals

40 B.T.A. 781; 1939 BTA LEXIS 799;

October 24, 1939, Promulgated

Petitioner and a realty corporation, owning and holding real estate which petitioner rented and used in its business, had substantially the same stockholders and officers, though there were some differences and the two corporations were operated as separate entities. , petitioner had loaned the realty company money in prior years and in 1934 took its…

2Cases cited1 opinion

  1. Huey & Philip Hardware Co. v. CommissionerUnited States Board of Tax Appeals · 1939

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