Kent Industrial Corp. v. Commissioner
United States Tax Court
X corporation, of which petitioner was transferee, was formed in 1945 for the purpose of acquiring title to certain real estate and selling it at a profit after obtaining tenants in the improved portion of the real estate in order to facilitate its sale. In the same year X sold the real estate at a profit and took a purchase money mortgage securing the unpaid portion of the purchase price.
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X corporation, of which petitioner was transferee, was formed in 1945 for the purpose of acquiring title to certain real estate and selling it at a profit after obtaining tenants in the improved portion of the real estate in order to facilitate its sale. In the same year X sold the real estate at a profit and took a purchase money mortgage securing the unpaid portion of the purchase price. No other real estate was acquired or sold by X. Held, the interest on the purchase money bond received by X in 1947 did not constitute "rents" within the meaning of section 502 (g) of the Internal Revenue…
1Opinion of the Court
Kent Industrial Corporation, in Dissolution, Kenneth Carroad, Gunhilde R. Carroad and Cecilia A. Menzel, Trustees, Petitioners, v. Commissioner of Internal Revenue, Respondent
Kent Industrial Corp. v. Commissioner
Docket No. 50787
United States Tax Court
25 T.C. 215; 1955 U.S. Tax Ct. LEXIS 56;
October 31, 1955, Filed
Decision will be entered for the respondent.
X corporation, of which petitioner was transferee, was formed in 1945 for the purpose of acquiring title to certain real estate and selling it at a profit after obtaining tenants in the improved portion of the real estate in order to…
2Cases cited2 opinions
- Thrift v. CommissionerUnited States Tax Court · 1950
- Kent Industrial Corp. v. CommissionerUnited States Tax Court · 1955