Kessmar Constr. Co. v. Commissioner
United States Tax Court
The promoters of a housing development of 315 homes, with the loans to be insured under section 213 of the National Housing Act, as amended, formed 16 nonprofit mutual corporations to hold title to land and contract for construction of houses in small groups. Funds were provided by a lender through its subsidiary corporation.
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The promoters of a housing development of 315 homes, with the loans to be insured under section 213 of the National Housing Act, as amended, formed 16 nonprofit mutual corporations to hold title to land and contract for construction of houses in small groups. Funds were provided by a lender through its subsidiary corporation. The promoters also formed the 16 petitioner corporations, each of which formed a joint venture with the lender's subsidiary to build the houses for one of the mutuals. A building corporation controlled by the promoters constructed and sold the houses under separate…
1Opinion of the Court
Reuce, Judge:
The respondent determined deficiencies in petitioners’ income tax for the fiscal period ended July 31,1955, as follows:
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The sole issue for decision is whether the respondent erred in determining that the 16 petitioners were part of a single integrated business enterprise and that a single minimum surtax exemption of $25,000 was allocable among them in the amount of $1,562.50 each, in accordance with section 269, section 482, section 1551, and other applicable provisions of the Internal Revenue Code of 1954.
Some facts are stipulated.
FINDINGS OF FACT.
The stipulation of…
2Cases cited9 opinions
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
- Thomas E. Snyder Sons Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- James Realty Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Thomas E. Snyder Sons Co. v. CommissionerUnited States Tax Court · 1960
- Shaw Constr. Co. v. CommissionerUnited States Tax Court · 1961
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Kessmar Construction Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Dillier v. CommissionerUnited States Tax Court · 1964
- Lewisville Inv. Co. v. CommissionerUnited States Tax Court · 1971
- The Louisville Store of Liberty, Ky., Inc. v. The United States, and Eight Related CasesUnited States Court of Claims · 1967
- Louisville Stone of Liberty, Ky., Inc. v. United StatesUnited States Court of Claims · 1967
12 more not listed; retrieve them via the Exa API.