Bonaire Development Co. v. Commissioner
United States Tax Court
The sole asset of N & V, a cash basis corporation, was a shopping center. It entered into a contract for the management of the property, which required N & V to pay $ 24,000 a year, at the rate of $ 2,000 per month. The entire $ 24,000 was paid during the first 5 months of the taxable year and deducted on its income tax return.
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The sole asset of N & V, a cash basis corporation, was a shopping center. It entered into a contract for the management of the property, which required N & V to pay $ 24,000 a year, at the rate of $ 2,000 per month. The entire $ 24,000 was paid during the first 5 months of the taxable year and deducted on its income tax return. Shortly before May 19, 1964, Branjon, Inc., purchased 100 percent of the stock of N & V. N & V was dissolved on May 19, 1964, and it distributed the shopping center in complete liquidation to Branjon, Inc. Held, the advance payment of management fees for services to be…
1Opinion of the Court
Bonaire Development Company, a California Corporation, Successor by Merger to Branjon, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Bonaire Development Co. v. Commissioner
Docket No. 4396-69
United States Tax Court
76 T.C. 789; 1981 U.S. Tax Ct. LEXIS 129;
May 14, 1981, Filed
Decision will be entered for the respondent.
The sole asset of N & V, a cash basis corporation, was a shopping center. It entered into a contract for the management of the property, which required N & V to pay $ 24,000 a year, at the rate of $ 2,000 per month. The entire $ 24,000 was paid during the first 5…
2Cases cited35 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Dobson v. CommissionerSupreme Court of the United States · 1944
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