Legal Opinion

Nielsen v. Commissioner

United States Tax Court

Decided November 27, 1973No. Docket Nos. 2893-70, 2894-70Published

For more than 5 years preceding Mar. 31, 1964, Oak Park operated a hospital in Stockton, Calif. On Aug. 14, 1961, Oak Park purchased a hospital in Los Angeles, Calif. Although the two hospitals shared some management and professional services, each hospital had a separate medical staff, served patients living primarily within its own geographical area, and functioned independently of the other hospital.

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For more than 5 years preceding Mar. 31, 1964, Oak Park operated a hospital in Stockton, Calif. On Aug. 14, 1961, Oak Park purchased a hospital in Los Angeles, Calif. Although the two hospitals shared some management and professional services, each hospital had a separate medical staff, served patients living primarily within its own geographical area, and functioned independently of the other hospital. After a dispute arose among the shareholders of Oak Park, an agreement was reached to split up Oak Park into two corporations. On Mar. 31, 1964, Oak Park distributed to a group of its…

1Opinion of the Court

Riener C. Nielsen, Petitioner v. Commissioner of Internal Revenue, Respondent; Gene E. Moffatt and Edith Moffatt, Petitioners v. Commissioner of Internal Revenue, Respondent

Nielsen v. Commissioner

Docket Nos. 2893-70, 2894-70

United States Tax Court

61 T.C. 311; 1973 U.S. Tax Ct. LEXIS 13; 61 T.C. No. 33;

November 27, 1973, Filed

Decisions will be entered for the respondent.

For more than 5 years preceding Mar. 31, 1964, Oak Park operated a hospital in Stockton, Calif. On Aug. 14, 1961, Oak Park purchased a hospital in Los Angeles, Calif. Although the two hospitals shared some management and…

2Cases cited8 opinions

  1. Coady v. CommissionerUnited States Tax Court · 1960
  2. United States v. W. W. Marett and Ruth MarettCourt of Appeals for the Fifth Circuit · 1963
  3. Elliott v. CommissionerUnited States Tax Court · 1959
  4. Badanes v. CommissionerUnited States Tax Court · 1962
  5. Burke v. CommissionerUnited States Tax Court · 1964

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