Legal Opinion

Bardes v. Commissioner

United States Tax Court

Decided March 26, 1962No. Docket Nos. 75650, 75652Published

Petitioner Oliver L. Bardes, in 1953 and 1956, respectively, purchased two pieces of land in Cincinnati and leased a portion of each piece to Bardes Corporation and Ilsco Corporation, respectively. These corporations were owned and controlled by petitioner, his wife, and two minor daughters. The leases were for a term of 12 years. The corporations immediately erected substantial factory buildings on the leased land. The buildings had a useful life of 40 years.

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Petitioner Oliver L. Bardes, in 1953 and 1956, respectively, purchased two pieces of land in Cincinnati and leased a portion of each piece to Bardes Corporation and Ilsco Corporation, respectively. These corporations were owned and controlled by petitioner, his wife, and two minor daughters. The leases were for a term of 12 years. The corporations immediately erected substantial factory buildings on the leased land. The buildings had a useful life of 40 years. Held, all the transactions here involved were bona fide business transactions made at arm's length and Oliver realized no dividend…

1Opinion of the Court

Oliver L. Bardes and Olive M. Bardes, Petitioners, v. Commissioner of Internal Revenue, Respondent. Ilsco Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bardes v. Commissioner

Docket Nos. 75650, 75652

United States Tax Court

37 T.C. 1134; 1962 U.S. Tax Ct. LEXIS 168;

March 26, 1962, Filed

Decisions will be entered under Rule 50.

Petitioner Oliver L. Bardes, in 1953 and 1956, respectively, purchased two pieces of land in Cincinnati and leased a portion of each piece to Bardes Corporation and Ilsco Corporation, respectively. These corporations were owned and controlled by…

2Cases cited5 opinions

  1. Helvering v. BruunSupreme Court of the United States · 1940
  2. M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
  3. Jaeger Motor Car Co. v. CommissionerCourt of Appeals for the Seventh Circuit · 1960
  4. Fort Wharf Ice Co. v. CommissionerUnited States Tax Court · 1954
  5. Bardes v. CommissionerUnited States Tax Court · 1962

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