Legal Opinion

Cohn v. Commissioner

United States Tax Court

Decided October 20, 1953No. Docket Nos. 25600, 25601, 25602, 25603Published

Security Construction Company, a partnership organized in May 1942, built houses for sale before wartime controls of private housing went into effect in February 1943. It received priorities to build multiple unit houses which it intended to sell under N. H. A. regulations, and, later, to build single unit houses which it intended to sell upon completion.

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Security Construction Company, a partnership organized in May 1942, built houses for sale before wartime controls of private housing went into effect in February 1943. It received priorities to build multiple unit houses which it intended to sell under N. H. A. regulations, and, later, to build single unit houses which it intended to sell upon completion. All of the defense housing, 178 houses, was completed in 1944, and 109 single unit houses were sold in 1944. Sixty-nine multiple unit houses were rented in 1944, and all were sold in 1945. Upon the evidence, held, that the partnership was…

1Opinion of the Court

Alice E. Cohn, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Cohn v. Commissioner

Docket Nos. 25600, 25601, 25602, 25603

United States Tax Court

21 T.C. 90; 1953 U.S. Tax Ct. LEXIS 44;

October 20, 1953, Promulgated

Decisions will be entered for the respondent.

Security Construction Company, a partnership organized in May 1942, built houses for sale before wartime controls of private housing went into effect in February 1943. It received priorities to build multiple unit houses which it intended to sell under N. H. A. regulations, and, later, to build single unit houses which…

2Cases cited9 opinions

  1. MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
  2. Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
  3. Commissioner of Internal Revenue v. BoeingCourt of Appeals for the Ninth Circuit · 1939
  4. King v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  5. Victory Housing No. 2, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1953

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