Legal Opinion

Leisure Time Enterprises, Inc. v. Commissioner

United States Tax Court

Decided August 26, 1971No. Docket No. 1119-69Published

In 1962 Shassian, a residential builder and developer, agreed to have facilities for a swim club constructed and to lease and then sell them to a community group organized for the purpose of operating the swim club. On May 16, 1962, Shassian organized L corporation and became its sole shareholder. Five days later L entered into a contract with the community group for the lease and sale of the swim club facilities.

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In 1962 Shassian, a residential builder and developer, agreed to have facilities for a swim club constructed and to lease and then sell them to a community group organized for the purpose of operating the swim club. On May 16, 1962, Shassian organized L corporation and became its sole shareholder. Five days later L entered into a contract with the community group for the lease and sale of the swim club facilities. Construction of the facilities continued through June of 1962. The facilities were sold on July 13, 1965, at a gain of $ 61,761.66. L was liquidated soon thereafter. Held, by reason…

1Opinion of the Court

Leisure Time Enterprises, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Leisure Time Enterprises, Inc. v. Commissioner

Docket No. 1119-69

United States Tax Court

56 T.C. 1180; 1971 U.S. Tax Ct. LEXIS 69;

August 26, 1971, Filed

Decision will be entered for the respondent.

In 1962 Shassian, a residential builder and developer, agreed to have facilities for a swim club constructed and to lease and then sell them to a community group organized for the purpose of operating the swim club. On May 16, 1962, Shassian organized L corporation and became its sole shareholder. Five days later…

2Cases cited18 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Bingler v. JohnsonSupreme Court of the United States · 1969
  4. Brewster v. GageSupreme Court of the United States · 1930
  5. Sanford v. CommissionerUnited States Tax Court · 1968

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