Burr Oaks Corp. v. Commissioner
United States Tax Court
Three individuals acquired a tract of undeveloped land in 1957 for $ 100,000. They decided to subdivide and improve the land, and sell lots therefrom. They incorporated petitioner in 1959 and transferred the land to it. In return, each received what purported to be a 2-year, 6-percent promissory note in the principal amount of $ 110,000. The land was not worth more than $ 165,000 when so transferred.
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Three individuals acquired a tract of undeveloped land in 1957 for $ 100,000. They decided to subdivide and improve the land, and sell lots therefrom. They incorporated petitioner in 1959 and transferred the land to it. In return, each received what purported to be a 2-year, 6-percent promissory note in the principal amount of $ 110,000. The land was not worth more than $ 165,000 when so transferred. At approximately the same time, the wives or brothers of the three individuals transferred a total of $ 4,500 cash to petitioner and received common stock in petitioner. Although the wives and…
1Opinion of the Court
Fat, Judge:
Respondent, pursuant to a statutory notice of deficiency, determined deficiencies in the income tax of petitioner Burr Oaks Corp. for its taxable years ended September 30,1958,1959, and 1960, in the respective amounts of $15,067.26, $52,595.26, and $16,-602.61. With regard to the various individual petitioners, respondent determined the following deficiencies in their respective income taxes:
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Petitioner Burr Oaks Corp. will hereinafter be referred to as the petitioner, and petitioners A. Aaron Elkind, Harold A. Watkins, and Maurice Ritz will hereinafter sometimes be…
2Cases cited24 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Marcello v. CommissionerUnited States Tax Court · 1964
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Tauber v. CommissionerUnited States Tax Court · 1955
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
19 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
- Nye v. CommissionerUnited States Tax Court · 1968
- Yale Ave. Corp. v. CommissionerUnited States Tax Court · 1972
- The Piedmont Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1968
- De Groff v. CommissionerUnited States Tax Court · 1970
35 more not listed; retrieve them via the Exa API.