Stahl v. Commissioner
United States Tax Court
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
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- Commissioner v. SternSupreme Court of the United States · 1958
- Standard Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1942
- Brown v. CommissionerUnited States Tax Court · 1961
11 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Allen v. CommissionerUnited States Tax Court · 1975
- Don v. CommissionerUnited States Tax Court · 1971
- University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971