Carty v. Commissioner
United States Tax Court
1. Upon the liquidation of Jerseymaid Milk Products Co., Inc. (a "captive creamery" of the five grocery chain customers which owned 80 percent of its stock at the time of its liquidation), on January 12, 1952, and the distribution of all of its assets to petitioners, held, no goodwill was distributed. 2. Respondent's determination of the fair market value of the automotive equipment of Jerseymaid Milk Products Co., Inc., distributed to petitioners on January 12, 1952,…
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1. Upon the liquidation of Jerseymaid Milk Products Co., Inc. (a "captive creamery" of the five grocery chain customers which owned 80 percent of its stock at the time of its liquidation), on January 12, 1952, and the distribution of all of its assets to petitioners, held, no goodwill was distributed. 2. Respondent's determination of the fair market value of the automotive equipment of Jerseymaid Milk Products Co., Inc., distributed to petitioners on January 12, 1952, sustained.
1Opinion of the Court
Withet, Judge:
Respondent has determined deficiencies in the income tax of petitioners and an addition to tax for the years and in the amounts as follows:
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Petitioner Market Basket, Docket No. 79270, claims an overpayment for the taxable year 1953 in the amount of $2,999.39.
The issues presented for our decision are the correctness of the respondent’s action in determining (1) that upon the liquidation of Jerseymaid Milk Products Co., Inc., on January 12, 1952, and the distribution of all of its assets to petitioners, goodwill in the amount of $537,500 was included among the assets…
2Cases cited13 opinions
- United States v. DavisSupreme Court of the United States · 1962
- In Re the Accounting of BrownNew York Court of Appeals · 1926
- Horton v. CommissionerUnited States Tax Court · 1949
- MacDonald v. CommissionerUnited States Tax Court · 1944
- Danco Co. v. CommissionerUnited States Tax Court · 1950
8 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Wilmot Fleming Engineering Co. v. CommissionerUnited States Tax Court · 1976
- Miller v. CommissionerUnited States Tax Court · 1963
- Basf Wyandotte Corp., Formerly Wyandotte Chemical Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1976
- Williams v. CommissionerUnited States Tax Court · 1989
- Estate of Palmer v. CommissionerUnited States Tax Court · 1986
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