Honigman v. Commissioner
United States Tax Court
National, a corporation whose principal business was the ownership and operation of commercial real estate, was principally owned by three families. National sold the Pantlind Hotel, a large hotel in downtown Grand Rapids, Mich., to Edith Honigman whose family owned approximately 35 percent of National's stock.
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National, a corporation whose principal business was the ownership and operation of commercial real estate, was principally owned by three families. National sold the Pantlind Hotel, a large hotel in downtown Grand Rapids, Mich., to Edith Honigman whose family owned approximately 35 percent of National's stock. The corporation reported as a loss in its tax return filed for that year, $ 806,888.30, the difference between the adjusted basis of the hotel and the amount paid by Edith. Within 3 months thereafter, National adopted a plan of complete liquidation, which plan qualified as a…
1Opinion of the Court
Withet, Judge:
The Commissioner has determined deficiencies in petitioners’ income taxes in the amounts and for the taxable years shown below:
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The transferee petitioners in docket No. 3893-68 through 3898-68 concede their liability for any income tax deficiency of National Building Corp. Due to certain concessions made by both parties, the primary issues to be decided are: (1) Whether the transfer in May 1963 of ownership of the Pantlind Hotel property from National Building Corp. to Pantlind Hotel Co. was in part a dividend distribution to Jason and Edith Honigman to the extent…
2Cases cited4 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Illinois Merchants Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Dellinger v. CommissionerUnited States Tax Court · 1959
- Baan v. CommissionerUnited States Tax Court · 1969
3Cited by25 opinions
- Wolfsen Land & Cattle Co. v. CommissionerUnited States Tax Court · 1979
- Estate of Durkin v. CommissionerUnited States Tax Court · 1992
- Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
- Jason L. Honigman and Edith Honigman, Petitioners-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Cross-AppellantCourt of Appeals for the Sixth Circuit · 1972
- Polyak v. CommissionerUnited States Tax Court · 1990
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