Legal Opinion

Stahl v. Commissioner

United States Tax Court

Decided July 29, 1963No. Docket Nos. 74890, 79580-79585UnpublishedCited by 4 opinions

S transferred a business in corporate form to University Hill Foundation. Foundation liquidated the corporation and leased the bulk of the assets to A, a corporation formed to operate the business, in which S and his family held a majority interest, for a period of 5 years ending February 28, 1955. A was to pay 80 percent of its profits as rent to Foundation, which was then to pass on 90 percent of those receipts to S until the original purchase price was paid in full.

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S transferred a business in corporate form to University Hill Foundation. Foundation liquidated the corporation and leased the bulk of the assets to A, a corporation formed to operate the business, in which S and his family held a majority interest, for a period of 5 years ending February 28, 1955. A was to pay 80 percent of its profits as rent to Foundation, which was then to pass on 90 percent of those receipts to S until the original purchase price was paid in full. Lease was not renewed but A continued to hold property until it was sold in August 1956, when A settled with Foundation. A…

1Opinion of the Court

Oscar C. Stahl and Sylvia Stahl, et al. 1 v. Commissioner.

Stahl v. Commissioner

Docket Nos. 74890, 79580-79585.

United States Tax Court

T.C. Memo 1963-201; 1963 Tax Ct. Memo LEXIS 145; 22 T.C.M. (CCH) 996; T.C.M. (RIA) 63201;

July 29, 1963

S transferred a business in corporate form to University Hill Foundation. Foundation liquidated the corporation and leased the bulk of the assets to A, a corporation formed to operate the business, in which S and his family held a majority interest, for a period of 5 years ending February 28, 1955. A was to pay 80 percent of its profits as rent to Foundation,…

2Cases cited16 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
  3. Commissioner v. SternSupreme Court of the United States · 1958
  4. Standard Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1942
  5. Brown v. CommissionerUnited States Tax Court · 1961

11 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  2. Allen v. CommissionerUnited States Tax Court · 1975
  3. Don v. CommissionerUnited States Tax Court · 1971
  4. University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971

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