Benedek v. Commissoner
United States Tax Court
The petitioners formed corporations for the construction of an apartment housing project. The corporations borrowed $ 21,719,300 on FHA-insured mortgage loans to construct the project and expended in such construction a total of $ 18,118,987. The corporations distributed to their stockholders, among whom were the petitioners, a total of $ 3,158,000 in 1949, 1950, and 1951. At such times, the value of the leaseholds on which the project was constructed was $ 1,517,333. Held:…
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The petitioners formed corporations for the construction of an apartment housing project. The corporations borrowed $ 21,719,300 on FHA-insured mortgage loans to construct the project and expended in such construction a total of $ 18,118,987. The corporations distributed to their stockholders, among whom were the petitioners, a total of $ 3,158,000 in 1949, 1950, and 1951. At such times, the value of the leaseholds on which the project was constructed was $ 1,517,333. Held: The corporations were collapsible corporations within the meaning of sec. 117(m), I.R.C. 1939, and more than 70 percent…
1Opinion of the Court
Louis Benedek and Janet Benedek, 1 et al., Petitioners v. Commissoner of Internal Revenue, Respondent
Benedek v. Commissoner
Docket Nos. 81900, 81901, 81902, 81903
United States Tax Court
50 T.C. 732; 1968 U.S. Tax Ct. LEXIS 85;
August 12, 1968, Filed
Decisions will be entered under Rule 50.
The petitioners formed corporations for the construction of an apartment housing project. The corporations borrowed $ 21,719,300 on FHA-insured mortgage loans to construct the project and expended in such construction a total of $ 18,118,987. The corporations distributed to their stockholders, among whom were…
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- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Burge v. CommissionerUnited States Tax Court · 1957
- Payne v. CommissionerUnited States Tax Court · 1958
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