Legal Opinion

Glenn v. Commissioner

United States Tax Court

Decided February 22, 1944No. Docket No. 108437Published

1. Petitioner in January 1933 transferred his home and other real property of less value to a corporation newly formed by him, in consideration of all of its stock, and hypothecated the stock to obtain listed stock which could be used as collateral with his creditors. Later he transferred life insurance and stock to the corporation. The corporation held the properties, but transacted no business.

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1. Petitioner in January 1933 transferred his home and other real property of less value to a corporation newly formed by him, in consideration of all of its stock, and hypothecated the stock to obtain listed stock which could be used as collateral with his creditors. Later he transferred life insurance and stock to the corporation. The corporation held the properties, but transacted no business. Held, on the facts, that the corporation should not be recognized as a taxable entity separate from the petitioner, and that there was no error in denying loss claimed upon liquidation of the…

1Opinion of the Court

Thomas K. Glenn, Petitioner, v. Commissioner of Internal Revenue, Respondent

Glenn v. Commissioner

Docket No. 108437

United States Tax Court

3 T.C. 328; 1944 U.S. Tax Ct. LEXIS 185;

February 22, 1944, Promulgated

Decision will be entered under Rule 50.

1. Petitioner in January 1933 transferred his home and other real property of less value to a corporation newly formed by him, in consideration of all of its stock, and hypothecated the stock to obtain listed stock which could be used as collateral with his creditors. Later he transferred life insurance and stock to the corporation. The corporation…

2Cases cited1 opinion

  1. Glenn v. CommissionerUnited States Tax Court · 1944

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