Court Holding Co. v. Commissioner
United States Tax Court
The petitioner is a corporation of two stockholders, husband and wife. The husband, who largely looked after the business, acting for the corporation, orally agreed to sell the corporate property, upon specified terms, and $ 1,000 was received on the purchase price. At a meeting between the parties for execution of formal contract of sale, the stockholders were informed that a sale by the corporation would cause imposition of heavy income taxes.
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The petitioner is a corporation of two stockholders, husband and wife. The husband, who largely looked after the business, acting for the corporation, orally agreed to sell the corporate property, upon specified terms, and $ 1,000 was received on the purchase price. At a meeting between the parties for execution of formal contract of sale, the stockholders were informed that a sale by the corporation would cause imposition of heavy income taxes. They refused to sell, but immediately caused the corporation to distribute the property in kind to them as a liquidation dividend, and they then…
1Opinion of the Court
Court Holding Company, a Florida Corporation, v. Commissioner of Internal Revenue, Respondent
Court Holding Co. v. Commissioner
Docket No. 111075
United States Tax Court
2 T.C. 531; 1943 U.S. Tax Ct. LEXIS 89;
August 9, 1943, Promulgated
Decision will be entered under Rule 50.
The petitioner is a corporation of two stockholders, husband and wife. The husband, who largely looked after the business, acting for the corporation, orally agreed to sell the corporate property, upon specified terms, and $ 1,000 was received on the purchase price. At a meeting between the parties for execution of formal…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- United States v. IshamSupreme Court of the United States · 1873
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
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