Van Heusden v. Commissioner
United States Tax Court
Petitioners held an option to purchase a tract of real property. In anticipation of the resale of the tract they formed a corporation to which they assigned the option. The corporation then consummated the purchase and resale, following which the assets of the corporation were distributed in complete liquidation to petitioners.
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Petitioners held an option to purchase a tract of real property. In anticipation of the resale of the tract they formed a corporation to which they assigned the option. The corporation then consummated the purchase and resale, following which the assets of the corporation were distributed in complete liquidation to petitioners. Held, the nonrecognition treatment of section 337, I.R.C. 1954, is not available to petitioners because the corporation was collapsible, sec. 341, I.R.C. 1954. Sec. 337(c) (1) (A).
1Opinion of the Court
Guy A. Van Heusden, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent; Estate of E. J. Van Heusden, Deceased, Transferee, Melanie Van Heusden, Executrix, and Title Insurance and Trust Company, as Special Administrator, and Applicant for Letters of General Administration as Successor Executor to Melanie Van Heusden, Executrix, Petitioner, v. Commissioner of Internal Revenue, Respondent
Van Heusden v. Commissioner
Docket Nos. 2358-63, 2357-63
United States Tax Court
44 T.C. 491; 1965 U.S. Tax Ct. LEXIS 65;
June 28, 1965, Filed
Decisions will be entered for the respondent.
Petition…
2Cases cited13 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
- Phillips v. Comissioner of Internal RevenueUnited States Tax Court · 1955
- Braunstein v. CommissionerSupreme Court of the United States · 1963
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