Legal Opinion

Lowy v. Commissioner

United States Tax Court

Decided December 6, 1960No. Docket No. 59265Published

Liability of stockholder-transferee of all of the assets of a wholly owned corporation for interest on deficiencies in tax due from the transferor for the years 1942 and 1943, begins on March 15, 1943, and March 15, 1944 (the due dates for the filing of returns and payment of taxes), where the value of the distributed assets substantially exceeded the amounts of the deficiencies, additions to tax, and potential interest owing by the transferor; such liability for interest is…

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Liability of stockholder-transferee of all of the assets of a wholly owned corporation for interest on deficiencies in tax due from the transferor for the years 1942 and 1943, begins on March 15, 1943, and March 15, 1944 (the due dates for the filing of returns and payment of taxes), where the value of the distributed assets substantially exceeded the amounts of the deficiencies, additions to tax, and potential interest owing by the transferor; such liability for interest is governed by section 292 of the Internal Revenue Code of 1939 and not by State law.

1Opinion of the Court

Leo L. Lowy, Petitioner, v. Commissioner of Internal Revenue, Respondent

Lowy v. Commissioner

Docket No. 59265

United States Tax Court

35 T.C. 393; 1960 U.S. Tax Ct. LEXIS 13;

December 6, 1960, Filed

Decision will be entered under Rule 50.

Liability of stockholder-transferee of all of the assets of a wholly owned corporation for interest on deficiencies in tax due from the transferor for the years 1942 and 1943, begins on March 15, 1943, and March 15, 1944 (the due dates for the filing of returns and payment of taxes), where the value of the distributed assets substantially exceeded the amounts of…

2Cases cited21 opinions

  1. Phillips v. CommissionerSupreme Court of the United States · 1931
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Lowy v. CommissionerUnited States Tax Court · 1960
  4. Koppers Co. v. CommissionerUnited States Tax Court · 1944
  5. Patterson v. SimsCourt of Appeals for the Fifth Circuit · 1960

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