James Armour, Inc. v. Commissioner
United States Tax Court
Two individuals were the sole stockholders of corporation A which conducted a construction business, and corporation B, which owned and leased to corporation A the necessary construction equipment. Corporation B transferred its construction equipment, its furniture and fixtures, and its automobiles to corporation A for cash and an account receivable equal to the fair market value thereof.
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Two individuals were the sole stockholders of corporation A which conducted a construction business, and corporation B, which owned and leased to corporation A the necessary construction equipment. Corporation B transferred its construction equipment, its furniture and fixtures, and its automobiles to corporation A for cash and an account receivable equal to the fair market value thereof. Corporation B then distributed all its assets, including its office building, to its stockholders in cancellation and redemption of their stock. The stockholders immediately leased the office building to…
1Opinion of the Court
AteiNS, Judge:
The respondent determined deficiencies in income tax as follows:
Docket No. 3504-62, James Armour, Inc.
Tamable year ended— Deficiency
Sept. 30, 1958-$752. 81
Sept. 30, 1959_ 42, 806. 55
Docket No. 3505-62, Armour Excavating, Inc.
Taxable year ended— Deficiency
May 31, 1960_ $58,262.10
Docket No. 3513-62, James Armour and Florence K. Armour
Taxable year ended— Deficiency
Dec. 31, 1959_$665, 944. 60
The petitioner James Armour, Inc., concedes the correctness of the respondent’s determination of a deficiency of $152.81 for the taxable year ended September 30,1958. Certain of the other issues…
2Cases cited31 opinions
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- United States v. LewisSupreme Court of the United States · 1951
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
- Stein v. CommissionerUnited States Tax Court · 1956
- Stern Bros. & Co. v. CommissionerUnited States Tax Court · 1951
26 more not listed; retrieve them via the Exa API.
3Cited by69 opinions
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- Berghash v. CommissionerUnited States Tax Court · 1965
- Wilson v. CommissionerUnited States Tax Court · 1966
- American Mfg. Co. v. CommissionerUnited States Tax Court · 1970
- Atlas Tool Co. v. CommissionerUnited States Tax Court · 1978
64 more not listed; retrieve them via the Exa API.