Kamis Engineering Co. v. Commissioner
United States Tax Court
P corporation and its wholly owned subsidiary, S, simultaneously adopted plans of liquidation and sold their assets to an unrelated third party.
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P corporation and its wholly owned subsidiary, S, simultaneously adopted plans of liquidation and sold their assets to an unrelated third party. The proceeds of both sales were forthwith distributed to the shareholders of P. Held, that all requirements of sec. 337(a) and (b), I.R.C. 1954, having been complied with, the provisions of sec. 337(c)(2), excluding a sec. 332 liquidation from the benefit of sec. 337, are inapplicable and S is entitled to such benefit in respect of the sale of its assets.
1Opinion of the Court
Kamis Engineering Company, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Kamis Engineering Co. v. Commissioner
Docket Nos. 1659-69, 1668-69, 1669-69, 1670-69, 1671-69
United States Tax Court
60 T.C. 763; 1973 U.S. Tax Ct. LEXIS 74; 60 T.C. No. 79;
August 27, 1973, Filed
Decisions will be entered under Rule 50.
P corporation and its wholly owned subsidiary, S, simultaneously adopted plans of liquidation and sold their assets to an unrelated third party. The proceeds of both sales were forthwith distributed to the shareholders of P. Held, that all requirements of sec. 337(a)…
2Cases cited15 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Schulde v. CommissionerSupreme Court of the United States · 1963
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- J. C. Penney Co. v. CommissionerUnited States Tax Court · 1962
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