Legal Opinion

Ferguson v. Commissioner

United States Tax Court

Decided October 17, 1966No. Docket No. 92137Published

Petitioner owned an automobile dealership business and all of the stock of a corporation which owned three parcels of real estate. The automobile business was conducted in one of the buildings owned by the real estate corporation.

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Petitioner owned an automobile dealership business and all of the stock of a corporation which owned three parcels of real estate. The automobile business was conducted in one of the buildings owned by the real estate corporation. In 1955 petitioner sold his automobile business to a corporation (owned by unrelated persons), referred to as Enterprises, under an arrangement whereby a portion of the gross sales of the business was to be paid by Enterprises into a so-called experimental department, the funds to be used "for experimental purposes." Petitioner had complete control over the…

1Opinion of the Court

Joseph B. Ferguson, Petitioner v. Commissioner of Internal Revenue, Respondent

Ferguson v. Commissioner

Docket No. 92137

United States Tax Court

47 T.C. 11; 1966 U.S. Tax Ct. LEXIS 30;

October 17, 1966, Filed

Decision will be entered under Rule 50.

Petitioner owned an automobile dealership business and all of the stock of a corporation which owned three parcels of real estate. The automobile business was conducted in one of the buildings owned by the real estate corporation. In 1955 petitioner sold his automobile business to a corporation (owned by unrelated persons), referred to as Enterprises,…

2Cases cited12 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Commissioner v. WheelerSupreme Court of the United States · 1945
  3. United Mercantile Agencies, Inc. v. CommissionerUnited States Tax Court · 1955
  4. F. W. Drybrough v. Commissioner of Internal Revenue, L. N. Simpson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
  5. Hadden v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931

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