Isis Windows, Inc. v. Commissioner
United States Tax Court
A transferred a business in corporate form to B, a charitable foundation. B liquidated the corporation and leased the bulk of the assets to C, a corporation formed to operate the business, in which A held a large minority interest. C was to pay 80 percent of its profits as rent to B, who was then to pass on 90 percent of those receipts to A until the original purchase price was paid in full.
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A transferred a business in corporate form to B, a charitable foundation. B liquidated the corporation and leased the bulk of the assets to C, a corporation formed to operate the business, in which A held a large minority interest. C was to pay 80 percent of its profits as rent to B, who was then to pass on 90 percent of those receipts to A until the original purchase price was paid in full. Held: (1) the transfer from A to B in this case constituted a bona fide sale of a capital asset. (2) C's rental payments were made for the use of the leased property and are deductible as ordinary and…
1Opinion of the Court
Isis Windows, Inc. (formerly Metal Window Corporation) v. Commissioner. Leavitt B. Glaze and Edith L. Glaze v. Commissioner.
Isis Windows, Inc. v. Commissioner
Docket Nos. 79289, 79290.
United States Tax Court
T.C. Memo 1963-176; 1963 Tax Ct. Memo LEXIS 162; 22 T.C.M. (CCH) 837; T.C.M. (RIA) 63176;
June 27, 1963
A transferred a business in corporate form to B, a charitable foundation. B liquidated the corporation and leased the bulk of the assets to C, a corporation formed to operate the business, in which A held a large minority interest. C was to pay 80 percent of its profits as rent to B, who…
2Cases cited5 opinions
- Casey v. CommissionerUnited States Tax Court · 1962
- Papineau v. CommissionerUnited States Tax Court · 1957
- Brown v. CommissionerUnited States Tax Court · 1961
- Union Bank, and Anna Goldenberg v. United States. Jerome Goldenberg and Helena Goldenberg v. United States. Ida Goldenberg v. United StatesUnited States Court of Claims · 1961
- Sprague Electric Co. v. CommissionerUnited States Tax Court · 1961
3Cited by6 opinions
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
- University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Stahl v. CommissionerUnited States Tax Court · 1963
- Allen v. CommissionerUnited States Tax Court · 1975
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
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