State-Adams Corp. v. Commissioner
United States Tax Court
In order to obviate anticipated difficulties with regard to the devolution of title to a valuable piece of Chicago real estate leased on a long-term "net lease" to a department store, petitioner corporation was organized to hold title to such real estate (and lease). It was not intended that petitioner would exercise any substantial business function with regard to this property or otherwise, and petitioner did not actually engage in business after its organization.
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In order to obviate anticipated difficulties with regard to the devolution of title to a valuable piece of Chicago real estate leased on a long-term "net lease" to a department store, petitioner corporation was organized to hold title to such real estate (and lease). It was not intended that petitioner would exercise any substantial business function with regard to this property or otherwise, and petitioner did not actually engage in business after its organization. Its only activities were the holding of title to such real estate, the taking of steps necessary to continue its own corporate…
1Opinion of the Court
State-Adams Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
State-Adams Corp. v. Commissioner
Docket No. 63473
United States Tax Court
32 T.C. 365; 1959 U.S. Tax Ct. LEXIS 168;
May 15, 1959, Filed
Decision will be entered under Rule 50.
In order to obviate anticipated difficulties with regard to the devolution of title to a valuable piece of Chicago real estate leased on a long-term "net lease" to a department store, petitioner corporation was organized to hold title to such real estate (and lease). It was not intended that petitioner would exercise any substantial business…
2Cases cited10 opinions
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Langdon L. Skarda, Carolyn A. Skarda, Lynell G. Skarda, Kathryn B. Skarda, Cash T. Skarda and Annabel S. Skarda v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1957
- Howard A. Jackson and Elizabeth D. Jackson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Skarda v. CommissionerUnited States Tax Court · 1956
- Given v. CommissionerCourt of Appeals for the Eighth Circuit · 1956
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