Legal Opinion

Borall Corp. v. Commissioner

United States Tax Court

Decided October 30, 1946No. Docket Nos. 2841, 2890, 2895UnpublishedCited by 1 opinion

In pursuance of a plan of liquidation of the petitioner, Borall Corporation, the directors passed a resolution reciting that the corporation declare a "liquidating dividend of $8.00 per share payable in cash or in two (2) shares of Thompson Automatic Arms Corporation stock at the valuation of $4.00 per share * * *." In accordance therewith, some stockholders received stock and the corporation sold the remaining shares and paid the remaining stockholders their liquidating…

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In pursuance of a plan of liquidation of the petitioner, Borall Corporation, the directors passed a resolution reciting that the corporation declare a "liquidating dividend of $8.00 per share payable in cash or in two (2) shares of Thompson Automatic Arms Corporation stock at the valuation of $4.00 per share * * *." In accordance therewith, some stockholders received stock and the corporation sold the remaining shares and paid the remaining stockholders their liquidating dividend in cash. Upon the evidence, held: (1) That the sale was for and on behalf of the corporation and it is taxable on…

1Opinion of the Court

Borall Corporation et al. * v. Commissioner.

Borall Corp. v. Commissioner

Docket Nos. 2841, 2890, 2895.

United States Tax Court

1946 Tax Ct. Memo LEXIS 45; 5 T.C.M. (CCH) 933; T.C.M. (RIA) 46256;

October 30, 1946

In pursuance of a plan of liquidation of the petitioner, Borall Corporation, the directors passed a resolution reciting that the corporation declare a "liquidating dividend of $8.00 per share payable in cash or in two (2) shares of Thompson Automatic Arms Corporation stock at the valuation of $4.00 per share * * *." In accordance therewith, some stockholders received stock and the…

2Cases cited13 opinions

  1. Tide Water Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Davidson v. CommissionerSupreme Court of the United States · 1938
  3. Nace Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Sugar Creek Coal & Mining Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Northport Shores v. CommissionerUnited States Board of Tax Appeals · 1935

8 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Don v. CommissionerUnited States Tax Court · 1971

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