Rodman v. Commissioner
United States Tax Court
Petitioner owned oil-producing properties and nonproducing properties. Petitioner also owned 100 percent of the stock of Petroleum and 80 percent of the stock of Oil. According to a prearranged plan, petitioner transferred his producing and nonproducing properties to Petroleum for additional stock of Petroleum.
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Petitioner owned oil-producing properties and nonproducing properties. Petitioner also owned 100 percent of the stock of Petroleum and 80 percent of the stock of Oil. According to a prearranged plan, petitioner transferred his producing and nonproducing properties to Petroleum for additional stock of Petroleum. Thereafter, petitioner and the 20-percent owners of Oil exchanged all of their stock in Petroleum and Oil for stock of Reading & Bates, an unrelated publicly held corporation. Petitioner conceded that his transfer of properties to Petroleum should be treated as a taxable sale to…
1Opinion of the Court
Iewin, Judge:
Respondent determined the following deficiencies in petitioners’ income tax:
Tear Deficiency
1966 _$320,474.65
1967 _ 5,104.13
Subsequent to the trial of this case the parties settled several issues concerning petitioner’s business expenses; however, two issues remain for decision: (1) Whether petitioner understated the amount of gain realized upon a sale of oil properties in 1966; and (2) whether petitioner received a constructive dividend when he purchased property from his wholly owned corporation in 1966.
FINDINGS OP PACT
Some of the facts have been stipulated. The stipulation…
2Cases cited5 opinions
- Cook v. TaitSupreme Court of the United States · 1924
- Philadelphia Park Amusement Co. v. United StatesUnited States Court of Claims · 1954
- Bar L Ranch, Inc., and in Intervention-Appellant v. Robert L. Phinney, United States of America, in Intervention-AppelleeCourt of Appeals for the Fifth Circuit · 1970
- Dellinger v. CommissionerUnited States Tax Court · 1959
- Ludlow v. CommissionerUnited States Tax Court · 1961
3Cited by6 opinions
- Smith v. CommissionerUnited States Tax Court · 1982
- Amerada Hess Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1975
- Amerada Hess Corporation, Successor by Merger to Hess Oil & Chemical Corporation (J. D. Callendar Financial Vice-Pres.) v. Commissioner of Internal Revenue. Amerada Hess Corporation, Successor by Merger to Hess Oil & Chemical Corporation (Harold N. Bast, Vice-Pres.) v. Commissioner of Internal Revenue. White Farm Equipment Company, a Delaware Corporation (Successor to Oliver Corporation, a Delaware Corp.) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1975
- Metro Auto Auction, Inc. v. CommissionerUnited States Tax Court · 1984
- Rodman v. CommissionerUnited States Tax Court · 1971
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