Harrison v. Commissioner
United States Tax Court
Petitioners, through their subch. S corporation, Twin Lakes, owned real estate in Colorado. The corporation also owned a note with a face value of $ 300,000 (basis $ 220,000) cosigned by Mt. Elbert Plamor Ranch, Inc., and Mason. Mason was the 100-percent shareholder of Mt. Elbert, and his liability on the note was limited to the value of the capital stock owned by him in Mt. Elbert.
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Petitioners, through their subch. S corporation, Twin Lakes, owned real estate in Colorado. The corporation also owned a note with a face value of $ 300,000 (basis $ 220,000) cosigned by Mt. Elbert Plamor Ranch, Inc., and Mason. Mason was the 100-percent shareholder of Mt. Elbert, and his liability on the note was limited to the value of the capital stock owned by him in Mt. Elbert. Mason was an energetic real estate developer and petitioners relied on his ability to increase the value of the area in which Twin Lakes held property and so increase the value of their holdings in Twin Lakes.…
1Opinion of the Court
M. Lucile Harrison, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Harrison v. Commissioner
Docket Nos. 4027-70, 4028-70, 4029-70, 4030-70, 4033-70, 6798-70
United States Tax Court
59 T.C. 578; 1973 U.S. Tax Ct. LEXIS 182; 59 T.C. No. 57;
January 29, 1973, Filed
Decisions will be entered under Rule 50.
Petitioners, through their subch. S corporation, Twin Lakes, owned real estate in Colorado. The corporation also owned a note with a face value of $ 300,000 (basis $ 220,000) cosigned by Mt. Elbert Plamor Ranch, Inc., and Mason. Mason was the 100-percent shareholder of Mt.…
2Cases cited31 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. DavisSupreme Court of the United States · 1962
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Connecticut Mutual Life Insurance v. SchaeferSupreme Court of the United States · 1877
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