Legal Opinion

Overland Corp. v. Commissioner

United States Tax Court

Decided April 9, 1964No. Docket No. 27836Published

1. Held, petitioner, a manufacturer of automobiles, did not realize net abnormal income within the meaning of section 721(a)(2)(C), I.R.C. 1939, during its fiscal years ended September 30, 1942 to 1945, inclusive, which is attributable to other years by reason of its engineering work performed in connection with the production of the 1/4-ton military vehicle known as the jeep. 2. Held, the transfer of the assets of Willys-Overland Co. to petitioner in 1936 pursuant to a…

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1. Held, petitioner, a manufacturer of automobiles, did not realize net abnormal income within the meaning of section 721(a)(2)(C), I.R.C. 1939, during its fiscal years ended September 30, 1942 to 1945, inclusive, which is attributable to other years by reason of its engineering work performed in connection with the production of the 1/4-ton military vehicle known as the jeep. 2. Held, the transfer of the assets of Willys-Overland Co. to petitioner in 1936 pursuant to a bankruptcy reorganization under section 77B of the Bankruptcy Act of 1926 did not qualify as a nontaxable exchange within…

1Opinion of the Court

The Overland Corporation, Formerly Willys-Overland Motors, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Overland Corp. v. Commissioner

Docket No. 27836

United States Tax Court

42 T.C. 26; 1964 U.S. Tax Ct. LEXIS 122;

April 9, 1964, Filed

Decision will be entered under Rule 50.

1. Held, petitioner, a manufacturer of automobiles, did not realize net abnormal income within the meaning of section 721(a)(2)(C), I.R.C. 1939, during its fiscal years ended September 30, 1942 to 1945, inclusive, which is attributable to other years by reason of its engineering work performed in…

2Cases cited19 opinions

  1. Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
  2. Helvering v. Cement Investors, Inc.Supreme Court of the United States · 1942
  3. American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
  4. Hazeltine Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1937
  5. W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946

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