Manassas Airport Industrial Park, Inc., a Dissolved Corporation v. Commissioner of Internal Revenue

Fourth Circuit

Manassas Airport Industrial Park, Inc., a Dissolved Corporation v. Commissioner of Internal Revenue

557 F.2d 1113, 40 A.F.T.R.2d (RIA) 5444, 1977 U.S. App. LEXIS 12817

CourtCourt of Appeals for the Fourth Circuit

DecidedJune 21, 1977

Docket76-2311

StatusPublished

This text of 557 F.2d 1113 (Manassas Airport Industrial Park, Inc., a Dissolved Corporation v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Manassas Airport Industrial Park, Inc., a Dissolved Corporation v. Commissioner of Internal Revenue, 557 F.2d 1113, 40 A.F.T.R.2d (RIA) 5444, 1977 U.S. App. LEXIS 12817 (4th Cir. 1977).

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Opinion

PER CURIAM:

This case presents the question of whether Manassas Airport Industrial Park, Inc. was a collapsible corporation, i.e. one formed or availed of for the construction of property with the objective of subsequent distribution of property to its stockholders and the realization by them of a substantial part of the gain attributable to that property, so that it did not qualify for nonrecognition of the gain realized on the preliquidation sale of its assets under 26 U.S.C. § 337 (1954).

We think that the Tax Court correctly held that it was and we affirm on its opinion. Manassas Airport Industrial Park, Inc., 66 T.C. 566 (1976).

AFFIRMED.

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PER CURIAM:

This case presents the question of whether Manassas Airport Industrial Park, Inc. was a collapsible corporation, i.e. one formed or availed of for the construction of property with the objective of subsequent distribution of property to its stockholders and the realization by them of a substantial part of the gain attributable to that property, so that it did not qualify for nonrecognition of the gain realized on the preliquidation sale of its assets under 26 U.S.C. § 337 (1954).

We think that the Tax Court correctly held that it was and we affirm on its opinion. Manassas Airport Industrial Park, Inc., 66 T.C. 566 (1976).

AFFIRMED.

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557 F.2d 1113, 40 A.F.T.R.2d (RIA) 5444, 1977 U.S. App. LEXIS 12817, Counsel Stack Legal Research, https://law.counselstack.com/opinion/manassas-airport-industrial-park-inc-a-dissolved-corporation-v-ca4-1977.

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