Legal Opinion

Callan v. Comm'r

United States Tax Court

Decided July 22, 1970No. Docket Nos. 6025-68, 6026-68Published

A and B were each 50 percent stockholders of C corporation. In 1965 C made liquidating distributions of all of their assets to A and B in exchange for all of their capital stock. Thereafter C conducted no business whatever.

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A and B were each 50 percent stockholders of C corporation. In 1965 C made liquidating distributions of all of their assets to A and B in exchange for all of their capital stock. Thereafter C conducted no business whatever. In 1968 the Commissioner determined that C was liable for personal holding company tax for the taxable periods Mar. 1, 1964, to Feb. 28, 1965, and Mar. 1 to Mar. 12, 1965. As transferees of C's assets, A and B were liable for any deficiencies in personal holding company tax. On Mar. 27, 1968, in order to avoid liability for the tax by taking advantage of the statutory…

1Opinion of the Court

Michael C. Callan, Petitioner v. Commissioner of Internal Revenue, Respondent; Thomas J. Callan, Jr., Petitioner v. Commissioner of Internal Revenue, Respondent

Callan v. Comm'r

Docket Nos. 6025-68, 6026-68

United States Tax Court

54 T.C. 1514; 1970 U.S. Tax Ct. LEXIS 93;

July 22, 1970, Filed

Decisions will be entered for the respondent.

A and B were each 50 percent stockholders of C corporation. In 1965 C made liquidating distributions of all of their assets to A and B in exchange for all of their capital stock. Thereafter C conducted no business whatever. In 1968 the Commissioner determined that C…

2Cases cited27 opinions

  1. Hellmich v. HellmanSupreme Court of the United States · 1928
  2. United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
  3. Nicholson v. CommissionerUnited States Board of Tax Appeals · 1935
  4. Shoenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
  5. Foster v. United StatesSupreme Court of the United States · 1938

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