D'Angelo Assoc., Inc. v. Commissioner
United States Tax Court
Petitioner was organized on June 21, 1960, for the purpose of becoming the owner of the real property and equipment used by D in his business. Petitioner issued five-sixths of its original shares to D's children for $ 12,500, and one-sixth to D's spouse for $ 2,500. The $ 15,000 was supplied by D and his spouse.
Read the full summary
Petitioner was organized on June 21, 1960, for the purpose of becoming the owner of the real property and equipment used by D in his business. Petitioner issued five-sixths of its original shares to D's children for $ 12,500, and one-sixth to D's spouse for $ 2,500. The $ 15,000 was supplied by D and his spouse. Shortly thereafter on June 30, 1960, in a transaction formally designated a sale, D transferred his business assets to petitioner in exchange for $ 15,000, the assumption of a liability of D secured by the property transferred, and a $ 96,000 obligation of petitioner payable to D on…
1Opinion of the Court
D'Angelo Associates, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
D'Angelo Assoc., Inc. v. Commissioner
Docket No. 4020-75
United States Tax Court
70 T.C. 121; 1978 U.S. Tax Ct. LEXIS 129; 70 T.C. No. 12;
May 2, 1978, Filed
Decision will be entered under Rule 155.
Petitioner was organized on June 21, 1960, for the purpose of becoming the owner of the real property and equipment used by D in his business. Petitioner issued five-sixths of its original shares to D's children for $ 12,500, and one-sixth to D's spouse for $ 2,500. The $ 15,000 was supplied by D and his spouse. Shortly…
2Cases cited36 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
31 more not listed; retrieve them via the Exa API.