Legal Opinion

Bresson v. Commissioner

United States Tax Court

Decided August 19, 1998No. Tax Ct. Dkt. No. 22824-96Published

In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $ 329,000 to an unrelated third party. Petitioner kept the proceeds from the sale.

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In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $ 329,000 to an unrelated third party. Petitioner kept the proceeds from the sale. On Mar. 5, 1993, J filed a tax return for its fiscal year ended Feb. 28, 1991, reporting a capital gain of $ 194,705 from the sale of the Alhambra property and a tax due of $ 49,683, which was not paid. On Aug. 1, 1993, petitioner…

1Opinion of the Court

PETER J. BRESSON, TRANSFEREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bresson v. Commissioner

Tax Ct. Dkt. No. 22824-96

United States Tax Court

111 T.C. 172; 1998 U.S. Tax Ct. LEXIS 43; 111 T.C. No. 6;

August 19, 1998, Filed

Decision will be entered for respondent.

In July 1990, J, a corporation, transferred to petitioner, its sole shareholder, real property situated in California (the Alhambra property) without receiving a reasonably equivalent value in exchange therefor. Immediately thereafter, petitioner sold the Alhambra property for $ 329,000 to an unrelated third party.…

Also in this document: Dissent.

2Cases cited39 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Aquilino v. United StatesSupreme Court of the United States · 1960
  3. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  4. United States v. BessSupreme Court of the United States · 1958
  5. United States v. SummerlinSupreme Court of the United States · 1940

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