Alameda Realty Corp. v. Commissioner
United States Tax Court
1. Husband and wife owned all the stock of a corporation. They received an offer to purchase the sole asset of the corporation, land and a building thereon, attempted to have the prospective purchaser buy the stock of the corporation, found this was unacceptable to him, and thereupon agreed to have the corporation sell the land and building, and within less than 12 months thereafter withdrew for their own use all the proceeds of the sale.
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1. Husband and wife owned all the stock of a corporation. They received an offer to purchase the sole asset of the corporation, land and a building thereon, attempted to have the prospective purchaser buy the stock of the corporation, found this was unacceptable to him, and thereupon agreed to have the corporation sell the land and building, and within less than 12 months thereafter withdrew for their own use all the proceeds of the sale. Held, a plan of complete liquidation was adopted within the meaning of section 337, I.R.C. 1954, shortly before the corporation contracted to sell the land…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in income tax, and addition to the tax under section 6653 (b) of the Internal Revenue Code of 1954 2 of Alameda Realty Corp. for the calendar year 1955 in the amounts of $31,005.44 and $15,502.72, respectively, and determined deficiencies in income tax, and addition to tax under section 6653(b), of Raymond E. and Irma M. Hanly for the calendar year 1955 in the amounts of $50,126.99 and $25,063.50, respectively. Respondent also determined that Raymond E. and Irma M. Hanly were liable as transferees of the assets of Alameda Realty Corp. for the…
2Cases cited5 opinions
- Mountain Water Co. v. CommissionerUnited States Tax Court · 1960
- Guild v. CommissionerUnited States Board of Tax Appeals · 1930
- T. T. Word Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- City Bank of Washington v. CommissionerUnited States Tax Court · 1962
- Barnhill v. United StatesCourt of Appeals for the Tenth Circuit · 1938
3Cited by28 opinions
- Kind v. CommissionerUnited States Tax Court · 1970
- Haley Bros. Constr. Corp. v. CommissionerUnited States Tax Court · 1986
- Maynard Hospital, Inc. v. CommissionerUnited States Tax Court · 1969
- Beauchamp & Brown Groves Co. v. CommissionerUnited States Tax Court · 1965
- Covered Wagon, Inc. v. CommissionerCourt of Appeals for the Eighth Circuit · 1966
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