Legal Opinion

Sherwood Properties v. Commissioner

United States Tax Court

Decided September 22, 1987No. Docket Nos. 25018-83, 25019-83Published

Freedland owned 89 percent of the stock of Freedland Ltd., a Canadian corporation. Freedland owned 50.01 percent and Sherwood owned 49.99 percent of the stock of Huron, a Canadian corporation. In June 1977, Huron sold all of its assets for $ 1 million. In July and August 1977, Huron advanced Freedland $ 500,000. Testimony was provided that the advances were to be used by Freedland to maintain the steel allocations of Huron in the United States.

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Freedland owned 89 percent of the stock of Freedland Ltd., a Canadian corporation. Freedland owned 50.01 percent and Sherwood owned 49.99 percent of the stock of Huron, a Canadian corporation. In June 1977, Huron sold all of its assets for $ 1 million. In July and August 1977, Huron advanced Freedland $ 500,000. Testimony was provided that the advances were to be used by Freedland to maintain the steel allocations of Huron in the United States. However, Freedland treated the advances on its books as loans payable which were ultimately repaid in April and May 1979. Held: The advances…

1Opinion of the Court

Sherwood Properties, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Freedland Industries Corp., Petitioner v. Commissioner of Internal Revenue, Respondent

Sherwood Properties v. Commissioner

Docket Nos. 25018-83, 25019-83

United States Tax Court

89 T.C. 651; 1987 U.S. Tax Ct. LEXIS 135; 89 T.C. No. 45;

September 22, 1987; As amended October 20, 1987 September 22, 1987, Filed

Decisions will be entered under Rule 155. 23

Freedland owned 89 percent of the stock of Freedland Ltd., a Canadian corporation. Freedland owned 50.01 percent and Sherwood owned 49.99 percent of the stock of…

2Cases cited21 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  4. Pulllman's Palace Car Co. v. Missouri Pacific Railway Co.Supreme Court of the United States · 1885
  5. Central Railroad & Banking Co. v. GeorgiaSupreme Court of the United States · 1876

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