Airport Grove Corp. Of Polk County v. United States

The question this case presents is whether the taxpayer presented sufficient evidence to create a jury question as to his “principal purpose” in forming fifteen corporations.

Roy L. Perdue and his wife owned and operated fifteen citrus groves in Alturas, Florida. In 1959 Perdue consulted John Miller, an attorney and accountant, concerning the desirability of incorporating the groves. On Miller’s advice, Per-due incorporated each grove separately, and on October 1, 1959, each corporation took title to a citrus grove. The Commissioner proposed tax deficiencies for the fiscal years 1960 and 1961…