Legal Opinion

Sterner v. Commissioner

United States Tax Court

Decided August 28, 1959No. Docket Nos. 64111, 64115, 64117, 64119Published

Held, that North and Stanton, Inc., and Hancock Court Apartments, Inc., were collapsible corporations within the definition of section 117(m) of the 1939 Code, and, therefore, that gains realized by petitioners upon sale of their stock in these corporations were gains attributable to property which is not a capital asset.

1Opinion of the Court

Ellsworth J. Sterner and Helen W. Sterner, Petitioners, v. Commissioner of Internal Revenue, Respondent. David Levy and Jennie Levy, Petitioners, v. Commissioner of Internal Revenue, Respondent. Barney Pivnick and Rose Pivnick, Petitioners, v. Commissioner of Internal Revenue, Respondent. Joseph Feldman and Sarah Feldman, Petitioners, v. Commissioner of Internal Revenue, Respondent

Sterner v. Commissioner

Docket Nos. 64111, 64115, 64117, 64119

United States Tax Court

32 T.C. 1144; 1959 U.S. Tax Ct. LEXIS 98;

August 28, 1959, Filed

Decisions will be entered for the respondent.

Held, that North and…

2Cases cited7 opinions

  1. Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
  2. 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
  3. Abbott v. CommissionerUnited States Tax Court · 1957
  4. Payne v. CommissionerUnited States Tax Court · 1958
  5. August v. CommissionerUnited States Tax Court · 1958

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