North American Service Co. v. Commissioner
United States Tax Court
1. The purchase of the stock of a highway advertising company, followed by the distribution of its assets to the acquiring corporation (petitioner) which continued to operate the old business in new corporate form, held, in substance, the purchase of assets so that petitioner is entitled to the cost of acquisition as its basis. 2. Proper allocation of cost to service contracts received in liquidation determined. 3. Interest accrued in 1951 on an outstanding loan from an…
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1. The purchase of the stock of a highway advertising company, followed by the distribution of its assets to the acquiring corporation (petitioner) which continued to operate the old business in new corporate form, held, in substance, the purchase of assets so that petitioner is entitled to the cost of acquisition as its basis. 2. Proper allocation of cost to service contracts received in liquidation determined. 3. Interest accrued in 1951 on an outstanding loan from an individual owning more than 50 per cent of petitioner's stock, but not paid within 2 1/2 months after the close of the…
1Opinion of the Court
Train, Judge:
Respondent determined deficiencies in income taxes of petitioner North American Service Co., Inc., for the period October 17,1951, to December 31, 1951, in the amount of $9,044.67 and of petitioners North American Service Co., Inc., et ah, for the calendar year 1952 in the amount of $37,874.62. The issues are:(1) Whether the liquidation of North American Service Co. on October 31, 1951, was a complete liquidation within the meaning of section 112(b) (6) of the Internal Revenue Code of 1939, as contended by the respondent, so that the basis of the assets acquired remains the same…
2Cases cited8 opinions
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
- Trianon Hotel Co. v. CommissionerUnited States Tax Court · 1958
- United States v. Frank N. Mattison and Ida G. MattisonCourt of Appeals for the Ninth Circuit · 1959
3 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- The South Bay Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Massey-Ferguson, Inc. v. CommissionerUnited States Tax Court · 1972
- Frederick Steel Co. v. CommissionerUnited States Tax Court · 1964
- Liflans Corporation v. The United StatesUnited States Court of Claims · 1968
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