Legal Opinion
Russell v. Commissioner
Court of Appeals for the Sixth Circuit
Decided October 27, 1987No. Nos. 86-1679, 86-1680PublishedCited by 2 opinions
1Opinion of the Court
BOYCE F. MARTIN, Jr., Circuit Judge.
Walter J. Russell and Cannonsburg Skiing Corporation appeal the Tax Court’s (T.C. Memo 1985-15) denial of their claim against the Commissioner. Taxpayers claim that they were wrongfully denied tax benefits when the Commissioner determined that a series of transactions by them constituted a complete liquidation under Section 332 of the Internal Revenue Code of 1954 (26 U.S.C.), that Section 334(b)(2) applied for purposes of calculating the basis of the corporation’s assets, and that there was no reorganization under Section 368(a)(1) of the Code nor any…
2Cases cited11 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Vivienne Rabidue v. Osceola Refining Company, a Division of Texas-American Petrochemicals, Inc.Court of Appeals for the Sixth Circuit · 1986
- Cortland Specialty Co. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1932
- Leon H. White v. Warren M. Bloomberg, Postmaster, United States Post Office Department to Be Known as the United States Postal ServiceCourt of Appeals for the Fourth Circuit · 1974
- Moder v. United StatesSupreme Court of the United States · 1933
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3Cited by2 opinions
- Clyde Brown, Jr. v. United StatesCourt of Appeals for the Sixth Circuit · 1989
- Russell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987