Legal Opinion

Garriss Inv. Corp. v. Commissioner

United States Tax Court

Decided January 29, 1982No. Docket Nos. 4364-80, 4365-80Unpublished

GIC's corporate charter was cancelled by North Carolina in 1967. Thereafter, the corporation continued to hold nominal legal title to real estate, but the property was developed and sold by H as a sole proprietor. In 1976 the corporation applied for reinstatement of its charter and commenced some business activity.

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GIC's corporate charter was cancelled by North Carolina in 1967. Thereafter, the corporation continued to hold nominal legal title to real estate, but the property was developed and sold by H as a sole proprietor. In 1976 the corporation applied for reinstatement of its charter and commenced some business activity. In the same year, H married P and transferred all of the stock in GIC to P. Held, GIC was neither a corporation nor an association taxable as a corporation, for tax purposes, from 1969 to February 9, 1976 and therefore is not taxable on the gains realized from the sales of property…

1Opinion of the Court

GARRISS INVESTMENT CORPORATION, Petitioner v COMMISSIONER OF INTERNAL REVENUE, Respondent; LOIS R. GARRISS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Garriss Inv. Corp. v. Commissioner

Docket Nos. 4364-80, 4365-80.

United States Tax Court

T.C. Memo 1982-38; 1982 Tax Ct. Memo LEXIS 705; 43 T.C.M. (CCH) 396; T.C.M. (RIA) 82038;

January 29, 1982.

GIC's corporate charter was cancelled by North Carolina in 1967. Thereafter, the corporation continued to hold nominal legal title to real estate, but the property was developed and sold by H as a sole proprietor. In 1976 the corporation…

2Cases cited12 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. Estate of BoschSupreme Court of the United States · 1967
  3. Bixby v. CommissionerUnited States Tax Court · 1972
  4. Morrissey v. CommissionerSupreme Court of the United States · 1935
  5. Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971

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