City Bank of Washington v. Commissioner
United States Tax Court
On May 29, 1959, the stockholders of City Bank adopted (1) a plan of complete liquidation and (2) a resolution approving the sale of City Bank's assets. The adoption of such plan culminated several months of activity during which representatives of both City Bank and the purchasers worked on the contemplated transaction and at all times material herein it was the intention of the purchasers, upon acquiring the requisite number of shares of stock, to liquidate City Bank.
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On May 29, 1959, the stockholders of City Bank adopted (1) a plan of complete liquidation and (2) a resolution approving the sale of City Bank's assets. The adoption of such plan culminated several months of activity during which representatives of both City Bank and the purchasers worked on the contemplated transaction and at all times material herein it was the intention of the purchasers, upon acquiring the requisite number of shares of stock, to liquidate City Bank. On May 26, 1959, City Bank, in anticipation of the adoption of a plan of liquidation, sold a portion of its Government…
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in the petitioner’s income tax for the year 1956 in the amount of $117,753.72 and for the taxable period January 1, 1959, to May 29, 1959, in the amount of $258,838.57. The year 1956 is here involved solely because of respondent’s disallowance of a net operating loss carryback to that year from 1959. The issues are (1) whether the loss realized by petitioner in the sale of certain United States Treasury obligations is to be recognized, which turns upon whether the sale took place before or after petitioner’s adoption of a plan of…
2Cases cited4 opinions
- Mountain Water Co. v. CommissionerUnited States Tax Court · 1960
- Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Virginia Ice & Freezing Corp. v. CommissionerUnited States Tax Court · 1958
- McDonald v. CommissionerUnited States Tax Court · 1961
3Cited by10 opinions
- Alameda Realty Corp. v. CommissionerUnited States Tax Court · 1964
- Beauchamp & Brown Groves Co. v. CommissionerUnited States Tax Court · 1965
- Howell v. CommissionerUnited States Tax Court · 1963
- West Street-Erie Boulevard Corporation v. United StatesCourt of Appeals for the Second Circuit · 1969
- George L. Riggs, Inc. v. CommissionerUnited States Tax Court · 1975
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