Beckett v. Commissioner
United States Tax Court
A corporation which had sustained approximately $ 1 million of losses in a hardware business entered into an agreement with two partners engaged in numerous real estate development activities as partners and controlling stockholders of corporations, whereby a real estate department was established to develop a subdivision, the funds therefor being furnished by the two partners through purchases of the preferred stock in the corporation for an amount which was approximately…
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A corporation which had sustained approximately $ 1 million of losses in a hardware business entered into an agreement with two partners engaged in numerous real estate development activities as partners and controlling stockholders of corporations, whereby a real estate department was established to develop a subdivision, the funds therefor being furnished by the two partners through purchases of the preferred stock in the corporation for an amount which was approximately two-fifths of the then value of the common stock of the corporation. The real estate department was operated…
1Opinion of the Court
OPINION
Since the record in this case is voluminous and the testimony of the witnesses in many respects confusing and in some respects contradictory, we believe it well to state in summary our view of the reasons which motivated Bryan and Federighi to enter into the agreement of October 18, 1954, and the primary purpose of each of them for making this agreement before proceeding to discuss the issues raised by the parties. As of July 1,1954, Bryan and his brother owned all the stock of a corporation which was operating primarily a retail and wholesale hardware business. The operation of this…
2Cases cited21 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Mill Ridge Coal Company v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Southern Ford Tractor Corp. v. CommissionerUnited States Tax Court · 1958
16 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Ach v. CommissionerUnited States Tax Court · 1964
- Rubin v. CommissionerUnited States Tax Court · 1971
- Audrey L. Zeeman, Individually and as of the Estate of Leon S. Lees, Jr. v. United StatesCourt of Appeals for the Second Circuit · 1968
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- Maxwell Hardware Company, a Corporation, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Ninth Circuit · 1965
19 more not listed; retrieve them via the Exa API.