Legal Opinion
Sun Properties, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided March 2, 1955No. 15052PublishedCited by 103 opinions
1Opinion of the Court
TUTTLE, Circuit Judge.
The sole question here is whether the district court erred in holding that the conveyance of a warehouse property to the taxpayer corporation by its sole stockholder, in form a sale, was in substance a contribution to capital. We deem it appropriate here to set forth verbatim the findings of fact and conclusions of law of the district court, 54-2 U. S. Tax Cases fl9528:
“1. The Court has jurisdiction of the parties and subject matter.
“2. The taxpayer corporation was formed by Henry Peacock, Jr., on August 25, 1947, and the certificate of incorporation was filed on August…
2Cases cited11 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Chisholm v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
6 more not listed; retrieve them via the Exa API.
3Cited by103 opinions
- In the Matter of Multiponics, Incorporated, Bankrupt. MacHinery Rental, Inc. And Carl Biehl v. William W. Herpel, TrusteeCourt of Appeals for the Fifth Circuit · 1980
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- United States v. Simon W. Henderson, Jr., Independent for the Estate of Louise R. Henderson, DeceasedCourt of Appeals for the Fifth Circuit · 1967
- Montclair, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1963
98 more not listed; retrieve them via the Exa API.