Legal Opinion

Adams v. Commissioner

United States Tax Court

Decided May 31, 1978No. Docket Nos. 6976-74, 6977-74, 6978-74, 6979-74, 6980-74, 6981-74Published

In 1970, A, a corporation owned by petitioner, acquired title to Blackacre and subsequently conveyed it and Whiteacre (which it owned) to Y corporation. Y was a wholly owned subsidiary of S, a private foundation under sec. 509, I.R.C. 1954, of which petitioner was a trustee.

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In 1970, A, a corporation owned by petitioner, acquired title to Blackacre and subsequently conveyed it and Whiteacre (which it owned) to Y corporation. Y was a wholly owned subsidiary of S, a private foundation under sec. 509, I.R.C. 1954, of which petitioner was a trustee. The properties were encumbered to the extent of $ 364,000 when conveyed to Y. A received $ 700,000 from Y on the transaction with the understanding that A or petitioner would satisfy the mortgage liability outstanding on each property. In December 1970, A was liquidated and petitioner succeeded to the assets and…

1Opinion of the Court

* Paul W. Adams, Petitioner v. Commissioner of Internal Revenue, Respondent; Paul W. Adams, Transferee, Petitioner v. Commissioner of Internal Revenue, Respondent

Adams v. Commissioner

Docket Nos. 6976-74, 6977-74, 6978-74, 6979-74, 6980-74, 6981-74

United States Tax Court

70 T.C. 373; 1978 U.S. Tax Ct. LEXIS 112;

May 31, 1978, Filed

Decisions will be entered for the petitioner in docket Nos. 6976-74, 6979-74, and 6981-74.

Decisions will be entered under Rule 155 in docket Nos. 6977-74, 6978-74, and 6980-74.

In 1970, A, a corporation owned by petitioner, acquired title to Blackacre and subsequently…

2Cases cited27 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. United States v. BessSupreme Court of the United States · 1958
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
  5. United States v. KahrigerSupreme Court of the United States · 1953

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