INI, Inc. v. Commissioner
United States Tax Court
P1 and P2 were engaged in the management and brokering of real property. As of November 1, 1984, P1 owned 100 percent of P2's outstanding stock and P1 and P2 elected to file consolidated income tax returns for each taxable year ending September 30, thereafter. In May 1988, J and C, the owners of P1, decided to separate P1 and P2, since J and C no longer agreed on how P1 and P2 should be operated.
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P1 and P2 were engaged in the management and brokering of real property. As of November 1, 1984, P1 owned 100 percent of P2's outstanding stock and P1 and P2 elected to file consolidated income tax returns for each taxable year ending September 30, thereafter. In May 1988, J and C, the owners of P1, decided to separate P1 and P2, since J and C no longer agreed on how P1 and P2 should be operated. In order to effectuate the separation of P1 and P2, J and C executed various legal documents and transferred various assets and liabilities between P1 and P2. For the taxable year ending September…
1Opinion of the Court
INI, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; SPALDING PARTNERS, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
INI, Inc. v. Commissioner
Docket Nos. 3156-93, 3368-94
United States Tax Court
T.C. Memo 1995-112; 1995 Tax Ct. Memo LEXIS 111; 69 T.C.M. (CCH) 2113;
March 20, 1995, Filed
Decisions will be entered under Rule 155.
P1 and P2 were engaged in the management and brokering of real property. As of November 1, 1984, P1 owned 100 percent of P2's outstanding stock and P1 and P2 elected to file consolidated income tax returns for each taxable year ending…
2Cases cited18 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Estate of Craft v. CommissionerUnited States Tax Court · 1977
- Woodbury v. CommissionerUnited States Tax Court · 1967
13 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Reichner v. Comm'rUnited States Tax Court · 2006
- Ryan v. CommissionerUnited States Tax Court · 1998