James v. Commissioner
United States Tax Court
Chicora Apartments, Inc., was formed to construct and operate an apartment project. In return for obtaining the financing for the project and an FHA commitment to insure such financing, James received 50 percent of Chicora's stock. The Talbots received the other 50 percent of the stock in return for their transfer to Chicora of appreciated land on which the apartment project was to be constructed.
Read the full summary
Chicora Apartments, Inc., was formed to construct and operate an apartment project. In return for obtaining the financing for the project and an FHA commitment to insure such financing, James received 50 percent of Chicora's stock. The Talbots received the other 50 percent of the stock in return for their transfer to Chicora of appreciated land on which the apartment project was to be constructed. Held: 1. The stock received by James was issued for services and not in exchange for property; the fair market value of the stock is taxable to James as ordinary income. 2. Since James received his…
1Opinion of the Court
William A. James and Beryl N. James, Petitioners v. Commissioner of Internal Revenue, Respondent; C. N. Talbot and Lula E. Talbot, Petitioners v. Commissioner of Internal Revenue, Respondent
James v. Commissioner
Docket Nos. 3165-67, 5153-67
United States Tax Court
53 T.C. 63; 1969 U.S. Tax Ct. LEXIS 38;
October 23, 1969, Filed
Decisions will be entered for the respondent.
Chicora Apartments, Inc., was formed to construct and operate an apartment project. In return for obtaining the financing for the project and an FHA commitment to insure such financing, James received 50 percent of Chicora's…
2Cases cited11 opinions
- Ruge v. Comm'rUnited States Tax Court · 1956
- Blum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
- United States v. William D. Frazell and Martha T. FrazellCourt of Appeals for the Fifth Circuit · 1964
- Hamrick v. CommissionerUnited States Tax Court · 1964
- Lanova Corp. v. Comm'rUnited States Tax Court · 1952
6 more not listed; retrieve them via the Exa API.