Likins-Foster Honolulu Corp. v. Commissioner
United States Tax Court
Ps were members of an affiliated group which filed consolidated returns during the years in issue. LFH was the common parent of the affiliated group. On August 29, 1962, LFH received final payment of a condemnation award as a result of condemnation litigation initiated by the United States in 1957 against properties owned by corporations of which LFH was a shareholder.
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Ps were members of an affiliated group which filed consolidated returns during the years in issue. LFH was the common parent of the affiliated group. On August 29, 1962, LFH received final payment of a condemnation award as a result of condemnation litigation initiated by the United States in 1957 against properties owned by corporations of which LFH was a shareholder. Held, such payment was received by LFH in exchange for its stock in the corporations and therefore constitutes personal holding company income within the meaning of section 543. Held further, amounts allocated to LFH as…
1Opinion of the Court
LIKINS-FOSTER HONOLULU CORP., ALIAMANU HOMES, LTD., LIKINS-FOSTER TOPEKA CORP., LIKINS-FOSTER SALINA CORP., LOMITA HOMES, INC., CARDIFF HOMES, INC., HIGHLAND PARK HOMES, INC., LIKINS-FOSTER OLATHE CORP., COCHITA PUMICE CO., BRIGGS RENTAL COMPANY, FOSTER HOMES, LTD., FOSTER DEVELOPMENT CORP., CENTRAL DEVELOPMENT CORP., CHAMPLIN CORP., ROY TURNER & ASSOCIATES, LTD., CIELO VISTA CORP., T. JACK FOSTER & SONS, INC., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Likins-Foster Honolulu Corp. v. Commissioner
Docket No. 5361-78.
United States Tax Court
T.C. Memo 1985-572; 1985 Tax Ct. Memo…
2Cases cited15 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Ach v. CommissionerUnited States Tax Court · 1964
- Central Illinois Public Service Co. v. United StatesSupreme Court of the United States · 1978
- Westover v. SmithCourt of Appeals for the Ninth Circuit · 1949
- Jefferson v. CommissionerUnited States Tax Court · 1968
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3Cited by4 opinions
- Golden v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
- Likins-Foster Honolulu Corp. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Likins-Foster Honolulu Corp. v. Commissioner Nternal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Robert Golden v. Comm'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 2008