Lafayette Extended Care, Inc. v. Commissioner
United States Tax Court
Due to impending changes in the Medicare Program, the owners and operators of a nursing home decided to sell the operating portion of the business. The owners redeemed 90 percent of their stock in exchange for most of the physical assets of the operating company and purchased the remaining equipment and fixtures. They sold their remaining 10 percent interest for $ 30,000, representing the net value of the company's tangible assets.
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Due to impending changes in the Medicare Program, the owners and operators of a nursing home decided to sell the operating portion of the business. The owners redeemed 90 percent of their stock in exchange for most of the physical assets of the operating company and purchased the remaining equipment and fixtures. They sold their remaining 10 percent interest for $ 30,000, representing the net value of the company's tangible assets. Integrally related to the sale was a leaseback of all the equipment, a consulting agreement whereby the husband-seller was to render advice, and service contracts…
1Opinion of the Court
LAFAYETTE EXTENDED CARE, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
Lafayette Extended Care, Inc. v. Commissioner
Docket Nos. 3853-75, 3854-75, 5724-75.
United States Tax Court
T.C. Memo 1978-233; 1978 Tax Ct. Memo LEXIS 277; 37 T.C.M. (CCH) 995; T.C.M. (RIA) 78233;
June 26, 1978, Filed
Due to impending changes in the Medicare Program, the owners and operators of a nursing home decided to sell the operating portion of the business. The owners redeemed 90 percent of their stock in exchange for most of the physical assets of the operating company and purchased the…
2Cases cited46 opinions
- Commissioner v. TellierSupreme Court of the United States · 1966
- Los Angeles Gas & Electric Corp. v. Railroad CommissionSupreme Court of the United States · 1933
- Cammarano v. United StatesSupreme Court of the United States · 1959
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Textile Mills Securities Corp. v. CommissionerSupreme Court of the United States · 1941
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