Legal Opinion

Bolger v. Commissioner

United States Tax Court

Decided March 8, 1973No. Docket Nos. 5033-68, 5755-68Published

Corporations were organized to acquire title to properties, issue promissory notes secured by mortgages, and execute leases in order to provide maximum financing by avoiding State law restrictions on loans to individuals, to provide a mechanism for limiting the personal liability of such individuals, and to facilitate multiple-lender financing.

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Corporations were organized to acquire title to properties, issue promissory notes secured by mortgages, and execute leases in order to provide maximum financing by avoiding State law restrictions on loans to individuals, to provide a mechanism for limiting the personal liability of such individuals, and to facilitate multiple-lender financing. Upon the consummation of the foregoing transactions, the corporations immediately transferred the properties to the individuals, subject to the mortgages and leases but without such individuals assuming any personal liability. Each corporation was…

1Opinion of the Court

David F. Bolger and Barbara A. Bolger, Petitioners v. Commissioner of Internal Revenue, Respondent

Bolger v. Commissioner

Docket Nos. 5033-68, 5755-68

United States Tax Court

59 T.C. 760; 1973 U.S. Tax Ct. LEXIS 162; 59 T.C. No. 75;

March 8, 1973, Filed

Decisions will be entered under Rule 50.

Corporations were organized to acquire title to properties, issue promissory notes secured by mortgages, and execute leases in order to provide maximum financing by avoiding State law restrictions on loans to individuals, to provide a mechanism for limiting the personal liability of such individuals, and to…

Also in this document: Dissent · Scott; Dissent · Quealy; Dissent · Goffe.

2Cases cited41 opinions

  1. Universal Camera Corp. v. National Labor Relations BoardSupreme Court of the United States · 1951
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Higgins v. SmithSupreme Court of the United States · 1940
  5. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943

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