Wanamaker Trustees v. Commissioner
United States Tax Court
1. Wholly owned subsidiary's purchase of parent corporation's stock from petitioners, who were practically the sole owners of parent, held not to result in a distribution to petitioners substantially equivalent to a taxable dividend under Internal Revenue Code, section 115 (g), since the subsidiary corporation did not cancel or redeem "its stock." Mead Corporation v. Commissioner (C. C. A., 3d Cir.), 116 Fed.
Read the full summary
1. Wholly owned subsidiary's purchase of parent corporation's stock from petitioners, who were practically the sole owners of parent, held not to result in a distribution to petitioners substantially equivalent to a taxable dividend under Internal Revenue Code, section 115 (g), since the subsidiary corporation did not cancel or redeem "its stock." Mead Corporation v. Commissioner (C. C. A., 3d Cir.), 116 Fed. (2d) 187, followed. 2. Income applied by petitioners, trustees of Pennsylvania testamentary trust, pursuant to agreement with beneficiaries, to the payment of state inheritance taxes…
1Opinion of the Court
Trustees Common Stock John Wanamaker Philadelphia Under Will of Rodman Wanamaker, Deceased, C. Stevenson Newhall, Robert H. Montgomery, George P. Orr, Rodman Barker, J. Leonard Replogle and John Rodman Wanamaker, Surviving and Succeeding Trustees, Petitioners, v. Commissioner of Internal Revenue, Respondent
Wanamaker Trustees v. Commissioner
Docket No. 15065
United States Tax Court
11 T.C. 365; 1948 U.S. Tax Ct. LEXIS 78;
September 27, 1948, Promulgated
Decision will be entered under Rule 50.
1. Wholly owned subsidiary's purchase of parent corporation's stock from petitioners, who were practically…
2Cases cited6 opinions
- United States v. MitchellSupreme Court of the United States · 1926
- Keith v. JohnsonSupreme Court of the United States · 1926
- Constable's EstateSupreme Court of Pennsylvania · 1930
- Crane's EstateSupreme Court of Pennsylvania · 1933
- Henris's EstateSuperior Court of Pennsylvania · 1913
1 more not listed; retrieve them via the Exa API.