Koppers Coal Co. v. Commissioner
United States Tax Court
1. Petitioner's predecessor, for a cash consideration of $ 7,600,000, acquired all of the capital stock of 6 West Virginia coal mining corporations. Before transfer of the stock, each of the 6 corporations distributed in liquidation to its stockholders all the assets of such corporation other than its physical operating assets and leases, and the stockholders in each instance assumed all the existing debts and liabilities of the corporation.
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1. Petitioner's predecessor, for a cash consideration of $ 7,600,000, acquired all of the capital stock of 6 West Virginia coal mining corporations. Before transfer of the stock, each of the 6 corporations distributed in liquidation to its stockholders all the assets of such corporation other than its physical operating assets and leases, and the stockholders in each instance assumed all the existing debts and liabilities of the corporation. The predecessor thereupon caused the transfer of all of the assets of these 6 corporations to a subsidiary corporation organized by it to own and operate…
1Opinion of the Court
Leech, Judge:
Respondent has determined deficiencies in income tax for the calendar years 1936 and 1937 of $60,696.83 and $147,588.44, respectively, and a deficiency in unjust enrichment tax for the calendar year 1936 in the sum of $24,403.39. Seventeen issues are framed by the pleadings. Certain of these are disposed of by stipulation, effect to which will be given in the settlement under Rule 50. Each issue will be set out separately hereinafter together with the facts pertaining thereto and the opinion thereon. Certain of the facts were stipulated and these we include by reference in our…
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