Ridge Realization Corp. v. Commissioner
United States Tax Court
Central States Electric Corp. and two subsidiary investment companies were reorganized in a chapter X bankruptcy reorganization.
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Central States Electric Corp. and two subsidiary investment companies were reorganized in a chapter X bankruptcy reorganization. As part of the plan of reorganization, petitioner was created for the sole purpose of prosecuting, realizing upon, and distributing the proceeds of two lawsuits which had been commenced by or on behalf of Blue Ridge Corp., one of the subsidiaries, seeking recovery from certain former directors of Blue Ridge and others for losses sustained by Blue Ridge as a result of alleged wrongdoing. In 1959 petitioner received $ 800,000 from one defendant in partial settlement…
1Opinion of the Court
Hoyt, Judge:
The respondent determined a deficiency in petitioner’s income tax for the calendar year 1959 in the amount of $387,990.58. The sole issue for decision is whether an amount of $800,000 recovered by petitioner in partial settlement of a litigation claim in 1959 must be included in taxable income.
FINDINGS OF FACT
Most of the facts have been stipulated. The stipulation of facts, supplemental stipulation of facts, and attached exhibits are incorporated herein by this reference. Some of the facts which have been agreed upon will be set forth hereinafter in detail.
Petitioner is a…
2Cases cited29 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Lyeth v. HoeySupreme Court of the United States · 1938
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
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3Cited by10 opinions
- Robert P. Shook and Barbara I. Shook v. United StatesCourt of Appeals for the Eleventh Circuit · 1983
- Fred E. Hudspeth v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
- Farley v. United StatesUnited States Court of Claims · 1978
- Lucille Howard v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Barrett v. CommissionerUnited States Tax Court · 1991
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