Legal Opinion

Estate of Goldenberg v. Commissioner

United States Tax Court

Decided May 14, 1964No. Docket Nos. 78723-78726UnpublishedCited by 4 opinions

The Goldenbergs transferred the stock of a corporation, the assets of a related partnership, and certain business real estate to the Foundation, a charitable organization.

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The Goldenbergs transferred the stock of a corporation, the assets of a related partnership, and certain business real estate to the Foundation, a charitable organization. The Foundation liquidated the corporation and leased certain assets of the business (the real estate, the machinery and equipment of the corporation, and certain intangibles) for a term of 5 years to Products, a corporation formed to operate the business, in which two of the Goldenbergs held a large minority interest. Products was to pay 80 percent of its profits as "rent" to the Foundation, which was then to pass on 90…

1Opinion of the Court

Estate of Sol Goldenberg, Deceased, Union Bank, Executor, and Anna Goldenberg, et al. 1 v. Commissioner.

Estate of Goldenberg v. Commissioner

Docket Nos. 78723-78726.

United States Tax Court

T.C. Memo 1964-134; 1964 Tax Ct. Memo LEXIS 201; 23 T.C.M. (CCH) 810; T.C.M. (RIA) 64134;

May 14, 1964

The Goldenbergs transferred the stock of a corporation, the assets of a related partnership, and certain business real estate to the Foundation, a charitable organization. The Foundation liquidated the corporation and leased certain assets of the business (the real estate, the machinery and equipment of the…

2Cases cited33 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  3. Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
  4. Michaels v. CommissionerUnited States Tax Court · 1949
  5. Place v. CommissionerUnited States Tax Court · 1951

28 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. Sparks Nugget, Inc. v. CommissionerUnited States Tax Court · 1970
  4. University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971

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