Estate of Goldstein v. Commissioner
United States Tax Court
1. The A. & A. Corporation had a general agency contract with an insurance company. Under this contract, the corporation obtained the rights to renewal commissions on all policies it placed with the insurance company. In 1950, the corporation liquidated and all its assets, including said rights, were distributed to its stockholders.
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1. The A. & A. Corporation had a general agency contract with an insurance company. Under this contract, the corporation obtained the rights to renewal commissions on all policies it placed with the insurance company. In 1950, the corporation liquidated and all its assets, including said rights, were distributed to its stockholders. Held, these rights did have an ascertainable fair market value at the time of distribution. 2. The fair market value of said rights at the time of distribution determined. 3. One of the stockholders died on November 16, 1953, and his portion of said rights passed…
1Opinion of the Court
FORRESTER, Judge:
The respondent has determined deficiencies in the income tax of Abraham Goldstein, deceased, and Anna Gold-stein, husband and wife, for the year 1953 in the amount of $2,259.66. A deficiency has also been determined in the income tax of Anna Goldstein, individually, for the year 1954 in the amount of $1,704.48.
The issues for decision are:
1. Whether certain rights to insurance renewal commissions distributed to stockholders upon the complete liquidation of a corporation had an ascertainable fair market value at the time of distribution.
2. If so, what was that fair market value.
2Cases cited8 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Burnet v. LoganSupreme Court of the United States · 1931
- Commissioner of Internal Revenue v. CarterCourt of Appeals for the Second Circuit · 1948
- Carter v. CommissionerUnited States Tax Court · 1947
- Westover v. SmithCourt of Appeals for the Ninth Circuit · 1949
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Warren Jones Co. v. CommissionerUnited States Tax Court · 1973
- Luce v. United StatesUnited States Court of Claims · 1983
- Dorsey v. CommissionerUnited States Tax Court · 1968
- Commissioner of Internal Revenue v. Estate of GoldsteinCourt of Appeals for the Second Circuit · 1965
- Clement v. United StatesDistrict Court, E.D. North Carolina · 1971
10 more not listed; retrieve them via the Exa API.