Elliott v. Commissioner
United States Tax Court
Centrifix Corporation bought an old house in 1946, occupying about half of it in its business and renting the remainder of it to others until it was sold in 1950, at which time it bought a larger building. Title to the new building was immediately transferred to a newly formed corporation, Centrifix Management Corporation, in April of 1950. Management rented about half the space in the new building to Centrifix and held the rest for rental to others.
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Centrifix Corporation bought an old house in 1946, occupying about half of it in its business and renting the remainder of it to others until it was sold in 1950, at which time it bought a larger building. Title to the new building was immediately transferred to a newly formed corporation, Centrifix Management Corporation, in April of 1950. Management rented about half the space in the new building to Centrifix and held the rest for rental to others. On December 15, 1954, Centrifix distributed all the stock of Management to Elliott, its principal stockholder, in exchange for all of…
1Opinion of the Court
DRennen, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1954 in the amount of $19,947.98 and additions to tax under section 294(d), I.R.C. 1939,1 in the amount of $3,395.87.
The only issue for determination is whether the distribution of all the stock of Centrifix Management Corporation, a wholly owned subsidiary, hereinafter referred to as Management, by Centrifix Corporation, hereinafter referred to as Centrifix, to Randall T. Elliott, the principal stockholder of Centrifix, on December 15, 1954, was taxable as a long-term capital gain to Elliott or…
2Cases cited5 opinions
- Bazley v. CommissionerSupreme Court of the United States · 1947
- Hazard v. CommissionerUnited States Tax Court · 1946
- Lagreide v. CommissionerUnited States Tax Court · 1954
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Fackler v. CommissionerUnited States Board of Tax Appeals · 1941
3Cited by24 opinions
- Henry H. Bonsall, Jr., and Martha G. Bonsall, C. Jordan Vail and Nancy B. Vail v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1963
- Appleby v. CommissionerUnited States Tax Court · 1961
- Lester v. CommissionerUnited States Tax Court · 1963
- Wilson v. CommissionerUnited States Tax Court · 1964
- Proctor v. CommissionerUnited States Tax Court · 1981
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