Santa Anita Consol., Inc. v. Commissioner
United States Tax Court
In 1957, LATC and CBS organized a corporation (POP) to construct and operate an amusement park, investing $ 1,800,000 in stock and guaranteeing a line of credit of $ 8,750,000. In 1959, LATC transferred its POP stock and $ 4,396,000 to Pacific, an unrelated corporation, and received a release of its liability as guarantor.
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In 1957, LATC and CBS organized a corporation (POP) to construct and operate an amusement park, investing $ 1,800,000 in stock and guaranteeing a line of credit of $ 8,750,000. In 1959, LATC transferred its POP stock and $ 4,396,000 to Pacific, an unrelated corporation, and received a release of its liability as guarantor. Held, LATC incurred an ordinary loss in 1959, deductible under sec. 165(a), I.R.C. 1954, of $ 4,396,000 on payment for its release from the guaranty obligation; held, further, LATC incurred a capital loss of $ 900,000 on the transfer of its POP stock to Pacific.
1Opinion of the Court
Santa Anita Consolidated, Inc. (Formerly Los Angeles Turf Club, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
Santa Anita Consol., Inc. v. Commissioner
Docket No. 3577-65
United States Tax Court
50 T.C. 536; 1968 U.S. Tax Ct. LEXIS 103;
July 2, 1968, Filed
Decision will be entered under Rule 50.
In 1957, LATC and CBS organized a corporation (POP) to construct and operate an amusement park, investing $ 1,800,000 in stock and guaranteeing a line of credit of $ 8,750,000. In 1959, LATC transferred its POP stock and $ 4,396,000 to Pacific, an unrelated corporation, and received a…
2Cases cited63 opinions
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