Lang v. Commissioner
United States Tax Court
Individual petitioners, the Langs, purchased all the stock of Kim-Sek, Ltd., which owned a ski lodge, for $ 742,000, represented by the Langs' notes. The ski lodge was carried on Kim-Sek's books at approximately $ 260,000. Several years later Kim-Sek was liquidated and all of its assets were transferred to a new corporation, Lang Properties, Inc., in which the Langs owned all the stock, in exchange for the assumption of liability on the Langs' note.
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Individual petitioners, the Langs, purchased all the stock of Kim-Sek, Ltd., which owned a ski lodge, for $ 742,000, represented by the Langs' notes. The ski lodge was carried on Kim-Sek's books at approximately $ 260,000. Several years later Kim-Sek was liquidated and all of its assets were transferred to a new corporation, Lang Properties, Inc., in which the Langs owned all the stock, in exchange for the assumption of liability on the Langs' note. Held, the Langs did not intend to liquidate Kim-Sek and acquire its assets when they purchased the Kim-Sek stock. Held,further, the liquidation…
1Opinion of the Court
HAROLD C. and VINNIE G. LANG, ET AL., 1 v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Lang v. Commissioner
Docket Nos. 8854-79, 8855-79, 8856-79.
United States Tax Court
T.C. Memo 1982-149; 1982 Tax Ct. Memo LEXIS 597; 43 T.C.M. (CCH) 874; T.C.M. (RIA) 82149;
March 24, 1982.
Individual petitioners, the Langs, purchased all the stock of Kim-Sek, Ltd., which owned a ski lodge, for $ 742,000, represented by the Langs' notes. The ski lodge was carried on Kim-Sek's books at approximately $ 260,000. Several years later Kim-Sek was liquidated and all of its assets were transferred to a new corporation,…
2Cases cited20 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Wall v. United StatesCourt of Appeals for the Fourth Circuit · 1947
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
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