Cane Creek Sportsman's Club, Inc. - Page 9

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          not what it is called, how many or how few own it, or how they              
          regard it.  Carver v. United States, supra at 237.                          
               Hooper and Chamblee, among others, created petitioner for              
          their joint advantage.  Real and substantial benefits inured to             
          petitioner's shareholders, including the privilege of limited               
          liability, the opportunity to continue petitioner's existence in            
          the event of a shareholder's death or withdrawal, the ability of            
          petitioner to hold title to and sell property, and the ability of           
          each individual shareholder to transfer his ownership interest in           
               Under the Internal Revenue Code, taxpayers are free to                 
          arrange their affairs as they choose; however, having made that             
          choice, they must accept the resulting tax consequences, whether            
          fully contemplated or not.  See Commissioner v. National Alfalfa            
          Dehydrating & Milling Co., 417 U.S. 134, 149 (1974).  Because               
          taxpayers may select the form in which they do business, the                
          choice of entity is generally binding.  Crouch v. United States,            
          692 F.2d 97, 99 (10th Cir. 1982); see also Bradley v. United                
          States, 730 F.2d 718, 720 (11th Cir. 1984).  Whatever the purpose           
          may have been in choosing to incorporate petitioner, so long as             
          that purpose is the equivalent of business activity or is                   
          followed by the corporation's carrying on business, the                     
          corporation remains a separate taxable entity.  See Moline                  
          Properties Inc. v. Commissioner, supra at 438-439.  We hold that            

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