Wofford v. Commissioner
United States Tax Court
1. Where a state court made an adjudication of ownership of property on the basis of an admission of such ownership by all parties to the suit, the Tax Court is not bound to accept such adjudication as conclusive. 2. A hotel building and private residence and other property operated as a business enterprise held to be the property of a corporation and not property owned by its stockholders in their individual capacity; and, upon the basis of such conclusion, it is further…
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1. Where a state court made an adjudication of ownership of property on the basis of an admission of such ownership by all parties to the suit, the Tax Court is not bound to accept such adjudication as conclusive. 2. A hotel building and private residence and other property operated as a business enterprise held to be the property of a corporation and not property owned by its stockholders in their individual capacity; and, upon the basis of such conclusion, it is further held, (a) that the distribution of the property, which constituted all of its assets, among the stockholders, under the…
1Opinion of the Court
OFINION.
Tyson, Judge:
The master made a distribution in the taxable year of the property involved in the suit in the Circuit Court of Dade County. The property so distributed consisted of (a) the proceeds of the sale of the hotel and residence and the furnishings therein (hereinafter referred to as the real estate) amounting to $256,500; (b) cash of $18,750.59 in the hands of Tatem Wofford and a balance of $4,040.71 in the bank account of the Wofford Hotel Corporation (hereinafter referred to as the cash funds); and (c) small items of cash, inventories, meter deposits, and prepaid taxes and…
2Cases cited7 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Curtis v. CommissionerUnited States Tax Court · 1944
2 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Hitchins v. CommissionerUnited States Tax Court · 1994
- Cloud v. CommissionerUnited States Tax Court · 1991
- Blackman v. CommissionerUnited States Tax Court · 1987
- Ingalls v. PattersonDistrict Court, N.D. Alabama · 1958
- Estate of Allen v. CommissionerUnited States Tax Court · 1982
15 more not listed; retrieve them via the Exa API.