Legal Opinion

Harrington v. Commissioner

United States Tax Court

Decided August 21, 1972No. Docket No. 6107-69Unpublished

P is the sole shareholder of S, a construction firm which has elected to be treated as a "subchapter S" corporation. In December 1964, S, which reports construction income on the percentage of completion method, agreed to complete the construction of a race track, and the construction was substantially completed in August 1965. As part of an agreement relating to such construction, S, in April and May 1965, received stock in M, the corporation owning the race track.

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P is the sole shareholder of S, a construction firm which has elected to be treated as a "subchapter S" corporation. In December 1964, S, which reports construction income on the percentage of completion method, agreed to complete the construction of a race track, and the construction was substantially completed in August 1965. As part of an agreement relating to such construction, S, in April and May 1965, received stock in M, the corporation owning the race track. S also was to receive a note for $1,250,000 payable in 3 years and bearing interest at the rate of 6 percent per annum. During…

1Opinion of the Court

Kenneth P. Harrington and Arola Harrington v. Commissioner.

Harrington v. Commissioner

Docket No. 6107-69.

United States Tax Court

T.C. Memo 1972-181; 1972 Tax Ct. Memo LEXIS 77; 31 T.C.M. (CCH) 888; T.C.M. (RIA) 72181;

August 21, 1972

P is the sole shareholder of S, a construction firm which has elected to be treated as a "subchapter S" corporation. In December 1964, S, which reports construction income on the percentage of completion method, agreed to complete the construction of a race track, and the construction was substantially completed in August 1965. As part of an agreement relating to…

2Cases cited9 opinions

  1. Steadman v. Comm'rUnited States Tax Court · 1968
  2. Charles W. Steadman and Dorothy F. Steadman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
  3. Portland Mfg. Co. v. CommissionerUnited States Tax Court · 1971
  4. Chicago & N. W. R. Co. v. CommissionerUnited States Tax Court · 1958
  5. Rand v. HelveringCourt of Appeals for the Eighth Circuit · 1941

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