Aqualane Shores, Inc. v. Commissioner
United States Tax Court
Three partners acquired certain real estate in 1949 as to which their adjusted basis was approximately $ 69,000. In 1950 they organized a corporation and conveyed the property to it at a price of $ 250,000 subject to a prior mortgage of approximately $ 50,000. They purported to subscribe in equal amounts to $ 9,600 of the corporation's stock and on the same day received a purported downpayment of $ 9,000. The corporation agreed to pay the balance of $ 191,000 in 5 annual…
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Three partners acquired certain real estate in 1949 as to which their adjusted basis was approximately $ 69,000. In 1950 they organized a corporation and conveyed the property to it at a price of $ 250,000 subject to a prior mortgage of approximately $ 50,000. They purported to subscribe in equal amounts to $ 9,600 of the corporation's stock and on the same day received a purported downpayment of $ 9,000. The corporation agreed to pay the balance of $ 191,000 in 5 annual installments for which no security was given. The corporation immediately needed considerable sums as working capital and…
1Opinion of the Court
The respondent determined deficiencies in the petitioner’s income taxes as follows:
1950-$7,105. 72
1951-,.- 9,999. 62
1952- 19,294.47
In view of certain concessions made by petitioner, the only question for our decision is whether the petitioner’s basis in certain property is the same as it was to its transferors, i. e., $69,291.93.
FINDINGS OF FACT.
Some of the facts in this case have been stipulated. The stipulation and the exhibits attached thereto are incorporated herein and made a part of our findings of fact by this reference.
Aqualane Shores, Inc., sometimes hereinafter referred to as the…
2Cases cited12 opinions
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Dobkin v. CommissionerUnited States Tax Court · 1950
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- Heller v. CommissionerUnited States Tax Court · 1943
7 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Aqualane Shores, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Baker Commodities, Inc. v. CommissionerUnited States Tax Court · 1967
- Burr Oaks Corp. v. CommissionerUnited States Tax Court · 1965
- Joe Goldstein and Lillian Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Knollwood Memorial Gardens v. CommissionerUnited States Tax Court · 1966
34 more not listed; retrieve them via the Exa API.