Legal Opinion

Knowlton v. Commissioner

United States Tax Court

Decided February 6, 1985No. Docket No. 22639-81 (Non-Nitrol Issues)Published

Petitioners received as part of a liquidating distribution from Dunmovin Corp. 24,950 shares of General Motors common stock, which Dunmovin had received after 1953 as a result of the court-ordered divestiture by E.I. duPont de Nemours & Co. of its interest in General Motors. Dunmovin acquired its interest in duPont prior to 1954. Held, the General Motors stock was, for purposes of sec. 333(e)(2), I.R.C. 1954, acquired by Dunmovin after Dec. 31, 1953.

1Opinion of the Court

John F. Knowlton and Betty W. Knowlton, Petitioners v. Commissioner of Internal Revenue, Respondent

Knowlton v. Commissioner

Docket No. 22639-81 (Non-Nitrol Issues)

United States Tax Court

84 T.C. 160; 1985 U.S. Tax Ct. LEXIS 126; 84 T.C. No. 11;

February 6, 1985. February 6, 1985, Filed

An order will be entered holding for respondent on the severed non-Nitrol issue.

Petitioners received as part of a liquidating distribution from Dunmovin Corp. 24,950 shares of General Motors common stock, which Dunmovin had received after 1953 as a result of the court-ordered divestiture by E.I. duPont de Nemours &…

2Cases cited19 opinions

  1. Commissioner v. BrownSupreme Court of the United States · 1965
  2. Dixon v. United StatesSupreme Court of the United States · 1965
  3. United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1957
  4. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  5. Helvering v. HammelSupreme Court of the United States · 1941

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