Abbott v. Commissioner
United States Tax Court
1. Corporation owning property with respect to which its stockholders (petitioners) agreed to cause conveyance, to procure F. H. A. commitments, and to have streets and other improvements installed, approved, dedicated, and paid for by corporation, held, to be "collapsible" under section 117 (m), I. R. C. 1939, so that gain realized by petitioners is ordinary income, notwithstanding that property was actually conveyed by stockholders after its distribution to them on…
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1. Corporation owning property with respect to which its stockholders (petitioners) agreed to cause conveyance, to procure F. H. A. commitments, and to have streets and other improvements installed, approved, dedicated, and paid for by corporation, held, to be "collapsible" under section 117 (m), I. R. C. 1939, so that gain realized by petitioners is ordinary income, notwithstanding that property was actually conveyed by stockholders after its distribution to them on dissolution, and that construction work was largely performed by independent contractors. 2. Failure to file a declaration of…
1Opinion of the Court
J. D. Abbott and Kathryn Abbott, Petitioners, v. Commissioner of Internal Revenue, Respondent. Carl M. Wolfe and Mary E. Wolfe, Petitioners, v. Commissioner of Internal Revenue, Respondent
Abbott v. Commissioner
Docket Nos. 52617, 52618
United States Tax Court
28 T.C. 795; 1957 U.S. Tax Ct. LEXIS 141;
June 28, 1957, Filed
Decisions will be entered for the respondent.
1. Corporation owning property with respect to which its stockholders (petitioners) agreed to cause conveyance, to procure F. H. A. commitments, and to have streets and other improvements installed, approved, dedicated, and paid for by…
2Cases cited15 opinions
- Acker v. CommissionerUnited States Tax Court · 1956
- Fuller v. CommissionerUnited States Tax Court · 1953
- Kaltreider v. CommissionerUnited States Tax Court · 1957
- Fuller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Smith v. CommissionerUnited States Tax Court · 1953
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