S. Tulsa Pathology Lab. v. Comm'r
United States Tax Court
P agreed to sell a portion of its business (clinical business) to N, a third party, pursuant to a prearranged sale that was structured as a spinoff.
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P agreed to sell a portion of its business (clinical business) to N, a third party, pursuant to a prearranged sale that was structured as a spinoff. P's basis in the clinical business's assets was $ 105,015. On Oct. 29, 1993, P transferred the clinical business to a newly incorporated entity, S, in exchange for all of S's stock, pursuant to sec. 368(a)(1)(D), I.R.C., and, on Oct. 30, 1993, P distributed the stock to P's shareholders in a transaction it claimed satisfied the requirements of sec. 355, I.R.C. On the same day as the distribution of S's stock to P's shareholders, S's shareholders…
1Opinion of the Court
SOUTH TULSA PATHOLOGY LABORATORY, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
S. Tulsa Pathology Lab. v. Comm'r
No. 18557-98
United States Tax Court
118 T.C. 84; 2002 U.S. Tax Ct. LEXIS 5; 118 T.C. No. 5;
January 28, 2002, Filed
Respondent's determination sustained.
P agreed to sell a portion of its business (clinical
business) to N, a third party, pursuant to a prearranged sale
that was structured as a spinoff. P's basis in the clinical
business's assets was $ 105,015. On Oct. 29, 1993, P transferred
the clinical business to a newly incorporated entity, S, in
exchange for all of S's…
2Cases cited12 opinions
- United States v. CartwrightSupreme Court of the United States · 1973
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Newhouse v. CommissionerUnited States Tax Court · 1990
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- Bd. of Regents, Etc. v. Natl. Collegiate Athletic Ass'nSupreme Court of Oklahoma · 1977
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