Bardes v. Commissioner
United States Tax Court
Petitioner Oliver L. Bardes, in 1953 and 1956, respectively, purchased two pieces of land in Cincinnati and leased a portion of each piece to Bardes Corporation and Ilsco Corporation, respectively. These corporations were owned and controlled by petitioner, his wife, and two minor daughters. The leases were for a term of 12 years. The corporations immediately erected substantial factory buildings on the leased land. The buildings had a useful life of 40 years.
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Petitioner Oliver L. Bardes, in 1953 and 1956, respectively, purchased two pieces of land in Cincinnati and leased a portion of each piece to Bardes Corporation and Ilsco Corporation, respectively. These corporations were owned and controlled by petitioner, his wife, and two minor daughters. The leases were for a term of 12 years. The corporations immediately erected substantial factory buildings on the leased land. The buildings had a useful life of 40 years. Held, all the transactions here involved were bona fide business transactions made at arm's length and Oliver realized no dividend…
1Opinion of the Court
AruNdell, Judge:
In these consolidated proceedings the respondent determined deficiencies in income taxes as follows:
Olives L. and Olote M. Bardes — Docket No. 75650
Year Deficiency
1953_ $67,656.08
1954_ 1, 763,134. 87
1955_ 383, 746.97
1956_ 492, 510.13
Ilsco Corporation — Docket No. 75652
1954_ 269, 580.94
1955_ 236,127. 51
1956_ 70, 815. 57
In determining these deficiencies the respondent made numerous adjustments to the net income reported by petitioners in their returns. Most of these adjustments were assigned as error by petitioners. However, the parties have now settled by stipulations most of…
2Cases cited4 opinions
- Helvering v. BruunSupreme Court of the United States · 1940
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- Jaeger Motor Car Co. v. CommissionerCourt of Appeals for the Seventh Circuit · 1960
- Fort Wharf Ice Co. v. CommissionerUnited States Tax Court · 1954
3Cited by4 opinions
- Boston Fish Market Corp. v. CommissionerUnited States Tax Court · 1972
- Human Engineering Institute v. CommissionerUnited States Tax Court · 1978
- Bardes v. CommissionerUnited States Tax Court · 1962
- Boston Fish Market Corp. v. CommissionerUnited States Tax Court · 1972