Legal Opinion

Pleasant Summit Land Corp. v. Commissioner

Court of Appeals for the Third Circuit

Decided November 25, 1988No. Nos. 88-1373, 88-1377PublishedCited by 34 opinions

1Opinion of the Court

OPINION OF THE COURT

GREENBERG, Circuit Judge.

Appellants, Pleasant Summit Land Corporation (PSLC) and George and Sharon *265Prussin, appeal from adverse decisions entered by the Tax Court following a consolidated trial on their petitions to redetermine deficiencies determined by the Commissioner of Internal Revenue. PSLC challenges the Tax Court’s conclusion that it was a “personal holding company” subject to the tax on personal holding companies in its tax year in issue. Resolution of its appeal depends on whether its sale of the Summit House apartments in West Orange, New Jersey, was of a…

2Cases cited33 opinions

  1. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  2. Pullman-Standard v. SwintSupreme Court of the United States · 1982
  3. Commissioner v. DubersteinSupreme Court of the United States · 1960
  4. Helvering v. TaylorSupreme Court of the United States · 1935
  5. Crane v. CommissionerSupreme Court of the United States · 1947

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3Cited by34 opinions

  1. Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
  2. Howard I. Lukens v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
  3. National Starch and Chemical Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
  4. Pnc Bancorp, Inc., Successor to First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16002) Pnc Bancorp, Inc., Transferee of Assets of First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16003) Pnc Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) Pnc Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) Pnc Bancorp, Inc., as (I) Successor to First National Pennsylvania Corporation, (Ii) Transferee of Assets of First National Pennsylvania Corporation, (Iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (Iv) Transferee of Assets of United Federal Bancorp, Inc., and SubsidiariesCourt of Appeals for the First Circuit · 2000
  5. Jonathan B. Geftman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1998

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