Simpson v. Commissioner
United States Tax Court
Legal title to apartment house property was held by a corporation of which petitioner was sole stockholder. Corporation sold the property for cash, assumption of mortgage, and a purchase money note. The Corporation was immediately liquidated under sec. 337, I.R.C. 1954, and the cash and note were distributed to petitioner. Held, the corporation was a viable entity and cannot be ignored for tax purposes. It was the seller of the real estate.
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Legal title to apartment house property was held by a corporation of which petitioner was sole stockholder. Corporation sold the property for cash, assumption of mortgage, and a purchase money note. The Corporation was immediately liquidated under sec. 337, I.R.C. 1954, and the cash and note were distributed to petitioner. Held, the corporation was a viable entity and cannot be ignored for tax purposes. It was the seller of the real estate. Held,further: The fair market value of the purchase money note received by petitioner on liquidation must be included in the amount petitioner received…
1Opinion of the Court
C.A. SIMPSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Simpson v. Commissioner
Docket No. 4120-72.
United States Tax Court
T.C. Memo 1976-160; 1976 Tax Ct. Memo LEXIS 239; 35 T.C.M. (CCH) 710; T.C.M. (RIA) 760160;
May 24, 1976, Filed
Legal title to apartment house property was held by a corporation of which petitioner was sole stockholder. Corporation sold the property for cash, assumption of mortgage, and a purchase money note. The Corporation was immediately liquidated under sec. 337, I.R.C. 1954, and the cash and note were distributed to petitioner. Held, the corporation was a…
2Cases cited16 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Strong v. CommissionerUnited States Tax Court · 1976
- Howard A. Jackson and Elizabeth D. Jackson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
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