Lesser v. Commissioner
United States Tax Court
1. Gain on the sale of houses in three separate real estate subdivisions held taxable to transferor corporations which acquired title to the land, built the houses thereon through a contractor but purportedly transferred the properties to their transferee stockholders just before the houses were deeded to the public.
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1. Gain on the sale of houses in three separate real estate subdivisions held taxable to transferor corporations which acquired title to the land, built the houses thereon through a contractor but purportedly transferred the properties to their transferee stockholders just before the houses were deeded to the public. In many instances the public bought the houses even before they were built and while the corporations still held title thereto. 2. While petitioners held liable as transferees for taxes due from the transferor corporations to the extent of the cash distributions made to them by…
1Opinion of the Court
Hoyt, Judge:
These proceedings involve transferee liabilities for 1950 income and excess profits taxes of three separate alleged transferor corporations. The deficiencies determined against the transferors and the transferee liabilities determined against each of the petitioners, being the alleged value of assets transferred to them, are as follows:
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The transferor corporations were all engaged in separate residential real estate developments in the Los Angeles area. Respondent has determined that the income realized on the sale of the houses and lots after tlie corporations had…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. SternSupreme Court of the United States · 1958
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Reis v. CommissionerUnited States Tax Court · 1942
15 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Quick Trust v. CommissionerUnited States Tax Court · 1970
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1985
- Troy State University v. CommissionerUnited States Tax Court · 1974
- Chagi v. CommissionerUnited States Tax Court · 1970
- EDDIE CORDES, INC. v. COMMISSIONERUnited States Tax Court · 2001
6 more not listed; retrieve them via the Exa API.