Manassas Airport Industrial Park, Inc. v. Commissioner
United States Tax Court
Petitioner purchased farmland and buildings which it held primarily for sale to customers in the ordinary course of its business. Petitioner constructed roads on the property and contemplated liquidation while construction of a road was in progress. Held: The collapsible corporation provisions of sec. 341, I.R.C. 1954, apply to real property not subject to depreciation.
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Petitioner purchased farmland and buildings which it held primarily for sale to customers in the ordinary course of its business. Petitioner constructed roads on the property and contemplated liquidation while construction of a road was in progress. Held: The collapsible corporation provisions of sec. 341, I.R.C. 1954, apply to real property not subject to depreciation. Petitioner realized only 9.3 percent of its total taxable income from the property prior to forming the intent to liquidate which is not a "substantial" part of the taxable income to be derived from the property. Accordingly,…
1Opinion of the Court
Manassas Airport Industrial Park, Inc., a Dissolved Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Manassas Airport Industrial Park, Inc. v. Commissioner
Docket No. 9166-72
United States Tax Court
66 T.C. 566; 1976 U.S. Tax Ct. LEXIS 83;
June 24, 1976, Filed
Decision will be entered for the respondent.
Petitioner purchased farmland and buildings which it held primarily for sale to customers in the ordinary course of its business. Petitioner constructed roads on the property and contemplated liquidation while construction of a road was in progress. Held: The collapsible…
2Cases cited26 opinions
- United States v. SanchezSupreme Court of the United States · 1950
- Braunstein v. CommissionerSupreme Court of the United States · 1963
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Sidney v. CommissionerUnited States Tax Court · 1958
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