Associates Inv. Co. v. Commissioner
United States Tax Court
Protective, a Nebraska corporation, was dissolved and during the 2-year period following its dissolution, its vice president executed consents which purported to extend the period for assessment of tax deficiencies for the years 1958 through 1962. The Nebraska Business Corporation Act, which is based on the Model Business Corporation Act, provides that upon dissolution, a corporation's existence ceases, except for certain limited purposes.
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Protective, a Nebraska corporation, was dissolved and during the 2-year period following its dissolution, its vice president executed consents which purported to extend the period for assessment of tax deficiencies for the years 1958 through 1962. The Nebraska Business Corporation Act, which is based on the Model Business Corporation Act, provides that upon dissolution, a corporation's existence ceases, except for certain limited purposes. Held, under Nebraska law, the execution of the consents during the post-dissolution period was authorized.
1Opinion of the Court
Associates Investment Company, Alleged Transferee of The Protective Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Associates Inv. Co. v. Commissioner
Docket No. 1426-69
United States Tax Court
59 T.C. 441; 1972 U.S. Tax Ct. LEXIS 8; 59 T.C. No. 42;
December 20, 1972, Filed
Protective, a Nebraska corporation, was dissolved and during the 2-year period following its dissolution, its vice president executed consents which purported to extend the period for assessment of tax deficiencies for the years 1958 through 1962. The Nebraska Business Corporation Act, which…
Also in this document: Concurrence.
2Cases cited20 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Chicago Title & Trust Co. v. Forty-One Thirty-Six Wilcox Bldg. Corp.Supreme Court of the United States · 1937
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
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