Legal Opinion

Freitas v. Commissioner

United States Tax Court

Decided May 24, 1966No. Docket Nos. 2519-62, 2703-62, 4829-62, 4830-62, 4799-63. T.C. Memo. 1966-105Unpublished

Corporation formed for the purpose of building and operating an apartment in Hawaii, held, not a collapsible corporation ( Sec. 341, I.R.C. 1954) where the plan to sell the stock of the corporate owner was not conceived until after the apartment building was completed. Gain on the sale of the stock of corporate owner, held, taxable as capital gain.

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Corporation formed for the purpose of building and operating an apartment in Hawaii, held, not a collapsible corporation ( Sec. 341, I.R.C. 1954) where the plan to sell the stock of the corporate owner was not conceived until after the apartment building was completed. Gain on the sale of the stock of corporate owner, held, taxable as capital gain. Held, further, installment method of reporting gain on the sale of the stock not now available to stockholder, who did not report the transaction in his return for the year of the sale, electing to report it in later years on the deferred payment…

1Opinion of the Court

George E. Freitas and Flora C. Freitas, et al. 1 v. Commissioner.

Freitas v. Commissioner

Docket Nos. 2519-62, 2703-62, 4829-62, 4830-62, 4799-63. T.C. Memo. 1966-105.

United States Tax Court

T.C. Memo 1966-105; 1966 Tax Ct. Memo LEXIS 177; 25 T.C.M. (CCH) 545; T.C.M. (RIA) 66105;

May 24, 1966

Corporation formed for the purpose of building and operating an apartment in Hawaii, held, not a collapsible corporation ( Sec. 341, I.R.C. 1954) where the plan to sell the stock of the corporate owner was not conceived until after the apartment building was completed. Gain on the sale of the stock of…

2Cases cited19 opinions

  1. Pacific National Co. v. WelchSupreme Court of the United States · 1938
  2. Thrift v. CommissionerUnited States Tax Court · 1950
  3. Reaver v. CommissionerUnited States Tax Court · 1964
  4. Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
  5. Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958

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