Adams v. Commissioner
United States Tax Court
In 1970, A, a corporation owned by petitioner, acquired title to Blackacre and subsequently conveyed it and Whiteacre (which it owned) to Y corporation. Y was a wholly owned subsidiary of S, a private foundation under sec. 509, I.R.C. 1954, of which petitioner was a trustee.
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In 1970, A, a corporation owned by petitioner, acquired title to Blackacre and subsequently conveyed it and Whiteacre (which it owned) to Y corporation. Y was a wholly owned subsidiary of S, a private foundation under sec. 509, I.R.C. 1954, of which petitioner was a trustee. The properties were encumbered to the extent of $ 364,000 when conveyed to Y. A received $ 700,000 from Y on the transaction with the understanding that A or petitioner would satisfy the mortgage liability outstanding on each property. In December 1970, A was liquidated and petitioner succeeded to the assets and…
1Opinion of the Court
Fay, Judge:
In these consolidated cases respondent determined chapter 42 excise tax deficiencies and additions to tax against Paul W. Adams, individually and as transferee of Automatic Accounting Co. (docket No. 6978-74) as follows:
Taxable Deficiency1 addition to tax
Docket No. 6977-74 ‘period or year 12/16/70-12/31/70 Sec. 4941(a)(1) $44.28 Sec. 4941(b)(1) $590.40 Sec. 6684 Sec. 6651(a) $11.07
1971 720.00 14,400.00 180.00
1972 360.00 14,400.00 90.00
6978-742 1970 35,515.10 1,420,604.00 $1,456,119.10 8,878.78
1971 35,515.10 8,878.78
1972 35,515.10 8,878.78
6980-743 12/16/70-12/31/70 34.44 688.80 8.61
1…
2Cases cited26 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. BessSupreme Court of the United States · 1958
- Commissioner v. SternSupreme Court of the United States · 1958
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- United States v. KahrigerSupreme Court of the United States · 1953
21 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Adams v. CommissionerUnited States Tax Court · 1979
- Estate of Reis v. CommissionerUnited States Tax Court · 1986
- Adams v. CommissionerUnited States Tax Court · 1978
- Bresson v. CommissionerUnited States Tax Court · 1998
- Lambos v. CommissionerUnited States Tax Court · 1987
31 more not listed; retrieve them via the Exa API.