Allen v. Commissioner
United States Tax Court
Petitioners, the owners of all the issued and outstanding shares of TCC, donated 77 percent of their shares to a charitable organization. Prior to the gift, TCC had adopted a plan of liquidation, and corporate resolutions had directed that all necessary action be taken to wind up the affairs of TCC and to distribute specified corporate assets to petitioners and to the contemplated charitable donee in complete liquidation so that no further authorization was required.
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Petitioners, the owners of all the issued and outstanding shares of TCC, donated 77 percent of their shares to a charitable organization. Prior to the gift, TCC had adopted a plan of liquidation, and corporate resolutions had directed that all necessary action be taken to wind up the affairs of TCC and to distribute specified corporate assets to petitioners and to the contemplated charitable donee in complete liquidation so that no further authorization was required. The assets were so distributed immediately following the transfer of the donated shares. Held, the transfers constituted an…
1Opinion of the Court
Horace E. Allen and Katherine M. Allen, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Allen v. Commissioner
Docket Nos. 8354-74, 2373-75
United States Tax Court
66 T.C. 340; 1976 U.S. Tax Ct. LEXIS 103;
May 24, 1976, Filed
Decisions will be entered for the respondent.
Petitioners, the owners of all the issued and outstanding shares of TCC, donated 77 percent of their shares to a charitable organization. Prior to the gift, TCC had adopted a plan of liquidation, and corporate resolutions had directed that all necessary action be taken to wind up the affairs of TCC and to…
2Cases cited27 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. HorstSupreme Court of the United States · 1940
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