Enoch v. Commissioner
United States Tax Court
Herbert Enoch desired to purchase the Gloria Homes, an apartment complex consisting of 423 apartments. Gloria Homes was owned by R.R.R., Inc., a corporation which had only 20 shares of stock issued and outstanding. Ten of these shares were owned by Simons, an individual, and the remaining 10 were owned by Sunrise Mining, a corporation which was 100-percent controlled by Simons.
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Herbert Enoch desired to purchase the Gloria Homes, an apartment complex consisting of 423 apartments. Gloria Homes was owned by R.R.R., Inc., a corporation which had only 20 shares of stock issued and outstanding. Ten of these shares were owned by Simons, an individual, and the remaining 10 were owned by Sunrise Mining, a corporation which was 100-percent controlled by Simons. The sales price for Gloria Homes was approximately $ 1,500,000. Enoch financed the purchase of the apartments in the following manner: (1) He invested in R.R.R. approximately $ 75,000 of his own capital; (2) he caused…
1Opinion of the Court
Herbert Enoch and Naomi Enoch, et al., 1a Petitioners v. Commissioner of Internal Revenue, Respondent
Enoch v. Commissioner
Dockets Nos. 511-67, 1834-67, 1835-67, 5216-68
United States Tax Court
57 T.C. 781; 1972 U.S. Tax Ct. LEXIS 163;
March 15, 1972, Filed
Decisions will be entered under Rule 50.
Herbert Enoch desired to purchase the Gloria Homes, an apartment complex consisting of 423 apartments. Gloria Homes was owned by R.R.R., Inc., a corporation which had only 20 shares of stock issued and outstanding. Ten of these shares were owned by Simons, an individual, and the remaining 10 were owned by…
Also in this document: Dissent · Raum; Dissent · Quealy.
2Cases cited44 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Douglas v. WillcutsSupreme Court of the United States · 1935
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