Roehner v. Gracie Manor, Inc.

Petitioner owns a 17½% interest in the respondent corporation, which was organized in 1954. It appears from the certificate of incorporation that the primary business of the corporation was the buying, selling, exchanging and leasing of real property. In 1955, the corporation constructed a multiple dwelling on East 85th Street in Manhattan. The management and operation of this building was the sole business activity of the respondent. In May, 1958, the property was sold for approximately $1,500,000 and the corporation received in cash approximately $350,000, representing the net amount over…