Legal Opinion
Gada v. United States
District Court, D. Connecticut
Decided September 12, 1978No. Civ. Nos. H-220ÂH-222PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OF DECISION FINDINGS OF FACT AND CONCLUSIONS OF LAW
CLARIE, Chief Judge.
This case encompasses three consolidated actions for the recovery of income taxes claimed by the plaintiffs to have been erroneously assessed for the tax year 1969. The issue before the Court is whether the issuance of shares of stock of two newly formed corporations to the shareholders of Guy’s Oil Service Station, Inc. (“Guy’s Oil”) constituted a tax free spin off pursuant to Internal Revenue Code (“I.R.C.”) § 355 and therefore was not a taxable distribution of corporate property under I.R.C. §§ 301 and 316.…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Weiss v. StearnSupreme Court of the United States · 1924
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Real Estate - Land Title & Trust Co. v. United StatesSupreme Court of the United States · 1940
- Commissioner v. GordonSupreme Court of the United States · 1968
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3Cited by3 opinions
- 303 West 42nd St. Enterprises, Inc. v. Internal Revenue ServiceCourt of Appeals for the Second Circuit · 1999
- Lutheran Social Service of Minn. v. United StatesDistrict Court, D. Minnesota · 1984
- Docket No. 97-6066 August Term, 1997Court of Appeals for the Second Circuit · 1999