Dunavant v. Commissioner
United States Tax Court
Petitioners were the sole officers, directors, and shareholders of their controlled corporation. The corporation adopted a plan of liquidation on Nov. 28, 1969, and all of its properties were distributed in liquidation on Dec. 21, 1969. Form 966 was filed by the corporation on Dec. 8, 1969, along with copies of the minutes of the shareholders meeting that authorized the liquidation, and the Statement of Intent to Dissolve filed under State law.
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Petitioners were the sole officers, directors, and shareholders of their controlled corporation. The corporation adopted a plan of liquidation on Nov. 28, 1969, and all of its properties were distributed in liquidation on Dec. 21, 1969. Form 966 was filed by the corporation on Dec. 8, 1969, along with copies of the minutes of the shareholders meeting that authorized the liquidation, and the Statement of Intent to Dissolve filed under State law. Only the directors' minutes referred to sec. 333, I.R.C. 1954. Petitioners have not filed Form 964. Held, petitioners are not qualified electing…
1Opinion of the Court
Lee R. Dunavant and Doris Dunavant, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Dunavant v. Commissioner
Docket Nos. 4562-73, 4563-73, 4564-73
United States Tax Court
63 T.C. 316; 1974 U.S. Tax Ct. LEXIS 10;
December 12, 1974, Filed
Decisions will be entered under Rule 155.
Petitioners were the sole officers, directors, and shareholders of their controlled corporation. The corporation adopted a plan of liquidation on Nov. 28, 1969, and all of its properties were distributed in liquidation on Dec. 21, 1969. Form 966 was filed by the corporation on Dec. 8, 1969, along with…
2Cases cited10 opinions
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Dougherty v. CommissionerUnited States Tax Court · 1973
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
- Dunavant v. CommissionerUnited States Tax Court · 1974
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