The Farmers Union Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
1Opinion of the Court
DUNIWAY, Circuit Judge.
In 1951, the Farmers Union Corporation operated a retail hardware business and also had substantial real estate holdings in San Jose, California. It desired to get out of the retail business, and transferred the inventory and related assets constituting that business to seven of its 134 shareholders, receiving in return 8000 of its 20,000 shares of stock. In its tax returns for 1951 it treated the transaction as a sale of inventory, claiming that it incurred a loss of $226,349.84, and reported a total loss of $246,952.11, $217,527.20 of which was attributed to this…
2Cases cited12 opinions
- Commissioner of Internal Revenue v. SA Woods MacH. Co.Court of Appeals for the First Circuit · 1932
- Dill Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1939
- Mills Estate, Inc. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Mills Estate, IncCourt of Appeals for the Second Circuit · 1953
- Standard Linen Service, Inc. v. CommissionerUnited States Tax Court · 1959
- Motion Picture Capital Corp. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1936
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3Cited by11 opinions
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- A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
- Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
- A.E. Staley Mfg. Co. v. CommissionerUnited States Tax Court · 1995
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